Gramm-Leach-Bliley (GLB) Privacy rules received an inordinate amount of attention in the pre-crisis compliance era. This is due to corporate structures that share consumer information, often without the customer's knowledge. To protect consumers against unauthorized sharing so that affiliates and other firms can market to your consumer, the Opt-Out Provisions of the Gramm-Leach-Bliley privacy rules require that companies tell consumers how they treat consumers' private information. In addition, the company must give the consumer the option to elect NOT to share that information. This results in the form the consumer receives, and the instructions they use to opt-out.
We still see MANY questions regarding this form and its proper completion, so we have provided this simple guide to correctly populating the form fields.
How to Correctly Complete the Form
- Add, income/employment, asset, credit history, property information as necessary
- YES - you send to investors and underwriters, as well as secondary market partners, title companies, etc.
- NO - they can't limit it because they wouldn't get a loan if you didn't share it.
- Depends on your marketing - do you market to your customers - past or present? (e.g. email blasts) If yes then yes, and your customer must be able to opt out and you have to have a toll-free number.