Reg P: Privacy Flashcards Preview

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Flashcards in Reg P: Privacy Deck (11)
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1
Q

WHO is covered under Reg P?

A

Consumers

2
Q

What is the difference between a consumer and a customer?

A

A consumer is a person who applies for, obtains, or has obtained a financial product or service that is to be used primarily for personal, family or household purposes.

A customer is any consumer who has a customer relationship (having a continued relationship over time) with the bank.

3
Q

What is non-public personal information?

A

Personally-identifiable financial information. In a nutshell, it’s everything you know about your customer.

4
Q

Banks can not disclose non-public personal information about consumers to non-affiliated third parties without what?

A

Providing an opt-out notice and waiting 30 days

5
Q

When must the bank provide the Privacy Policy to customers?

A

At the time the relationship is established (in writing) and annually thereafter (or published on the website)

6
Q

When must the bank provide an opt-out notice in the privacy policy?

A

If the bank plans to share information with a non-affiliated third party.

7
Q

What are the three exceptions for providing non-public personal information about a customer to non-affiliated third parties?

A

Marketing
Processing or servicing
Miscellaneous

8
Q

A bank may provide customer information to a non-affiliated third party to perform services for the bank or functions on the bank’s behalf if the bank has done what two things?

A
  • Provided the privacy notice to the customer and

- Entered into a contract with the third party

9
Q

T/F: The bank may provide information to a non-affiliated third party as necessary to carry out a transaction for a consumer or to administer or maintain the product or service of which the transaction is a part without allowing the consumer to opt-out of that sharing.

A

True

10
Q

T/F: The bank may NOT provide information to a non-affiliated third party to service or process a product or service requested or authorized by the consumer without allowing the consumer to opt-out of that sharing.

A

False, they are permitted to do so. This is an exception.

11
Q

What is the “miscellaneous” exception under Reg P for allowing banks to share NPPI without allowing the consumer to opt out of that sharing?

A

Laundry list of exceptions, such as providing info to regulators, courts, credit bureaus, ratings agencies, attorneys, accountants, or as required by law, etc.