vendor providing escrow acct service-? privacy

Posted By: Chocaholic

vendor providing escrow acct service-? privacy - 06/08/15 07:14 PM

We have recently established a relationship with another bank to provide the servicing for our home mortgages with escrow accounts- they have thousands of accounts on the books and we have less than 50 at this time.

My question has to do with the privacy notice we provide currently we do not share any information and as such do not provide the opt-out language in our disclosure - my thoughts are that this type of service still falls under the exemption #14 because they are using the non-public information they have to provide an account statement. Is this correct? I would appreciate any thoughts on this matter.
Posted By: Carolina Blue

Re: vendor providing escrow acct service-? privacy - 06/11/15 04:32 PM

Correct. You are sharing this information to complete a transaction. The customer does not have the ability to opt-out of that sharing.