A credit union's mortgage department shares customer payment history information with the credit union's investment services division to market investment products. Both divisions are part of the same credit union. Under GLBA, this practice is:
Correct Answer
D) Permitted only if customers are given opt-out notice and opportunity
Under GLBA, sharing nonpublic personal information between affiliates (including divisions of the same institution) for marketing purposes requires providing customers with an opt-out notice and reasonable opportunity to opt out, unless an exception applies. This is governed by the affiliate marketing provisions of the Fair Credit Reporting Act as implemented through GLBA.
Why This Is the Correct Answer
Under GLBA, sharing nonpublic personal information between affiliates (including divisions of the same institution) for marketing purposes requires providing customers with an opt-out notice and reasonable opportunity to opt out, unless an exception applies. This is governed by the affiliate marketing provisions of the Fair Credit Reporting Act as implemented through GLBA.
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