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Wednesday, January 24, 2007



Anyone identified in the financial institution's privacy notice. The regs list the following as examples of how the recipients of the information might be described: mortgage bankers, securities broker-dealers, insurance agents, retailers, magazine publishers, airlines, and direct marketers. 16 C.F.R. § 313.6(c)(3).


And "third party" means anyone whatsover?

Jeff Sovern

Under § 6802 of the Gramm-Leach-Blilely Act (GLB), financial institutions are permitted to share nonpublic personal infromation with unaffiliated third parties as long as they comply with GLB's notice and opt-out provisions (the Fair Credit Reporting Act governs disclosures to affiliates). Nonpublic personal information is defined in § 6809(4) as meaning personally identifiable financial information provided by a consumer to a financial insititution, resulting from any transaction with the consumer, or otherwise obtained by the financial institution. Lenders in the past have sold information to telemarketers, for example. A survey conducted by America's Communty Bankers and published as a supplement to the Wash. Perspective on Dec. 3, 2001 reported that about half the financial institutions with assets exceeding $1 billion share consumer information with non-affiliated third parties.



If you have the time, can you describe on the blog what information financial institutions are permitted to share, and with whom, if the consumer does NOT opt out? It is hard to gauge the importance of this issue without knowing that.


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