Privacy: Sharing with Affiliates
The Privacy Rule (Regulation P) governs your ability to share a consumer’s nonpublic personal information with nonaffiliated third parties. Generally, you can’t share such information with nonaffiliates, but there are a lot of exceptions. For instance, you can share with a nonaffiliated third party if the consumer authorizes it; you can share information to order checks; and you can provide a loan payoff amount to another lender, etc. Sharing with your affiliates is a different story because the Fair Credit Reporting Act has something to say about that. It’s important to understand this as you might be required to provide the consumer an opt-out.
Kevin explains more in the video.
Published
2024/06/28
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Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).