Academic journal article ABA Banking Journal

Sharing Private Info with a Privacy Vendor

Academic journal article ABA Banking Journal

Sharing Private Info with a Privacy Vendor

Article excerpt

Q. We recently entered into an agreement with e non-affiliated party to provide on ID theft/fraud protection solution to our customers. We do not shore customer information with the potty unless our customer signs up for the fraud protection product, at which time they ore provided information about the company with the membership kit. The nonaffiliated party is originating on ACH debit to charge to our customer's account for the fraud solution premiums. Is this on issue regarding the provision of the customer's information under the privacy account disclosure rules? What other protections might apply?

A. Under Regulation P, if this is a service that is processed mat the request of the customer, it falls under the exceptions contained in Section 216.14: "Exceptions to notice and opt out requirements for processing and servicing transactions." These read as follows:

"(a) Exceptions for processing transactions at consumer's request. The requirements for initial notice in Section 216.4(a)(2), for the opt out in Sections 216. …

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