Academic journal article ABA Banking Journal

What Duties Do Banks Have for Special Communications with the Deaf?

Academic journal article ABA Banking Journal

What Duties Do Banks Have for Special Communications with the Deaf?

Article excerpt

Q. We have some privacy concerns about the use of the TRS, TTY, or TDD communication devices for the deaf, in that we are often providing nonpublic personal information to our customer through a nonaffiliated third party. Do I need to be concerned about this? (Editor's Note: The acronyms stand for "Telecommunications Relay Service," "Teletypewriter," and "Telecommunications Device for the Deaf.")

A. From a privacy perspective, you have no real concerns. Section 216.14 of Regulation P contains exceptions to notice and opt-out requirements, and it states that these provisions do not apply if you disclose nonpublic, personal information "as necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes, or in connection with servicing or processing a financial product or service that a consumer requests or authorizes." Because your customer is requesting or authorizing that the communication be facilitated by the third-party provider, this should alleviate any requirements under Reg P.

With respect to fraud/"red flags" considerations, you need to look at this as part of your "red flags" assessment, although the risk is relatively low. …

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