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A mortgage lender's privacy notice states that customer information may be shared with 'companies that perform marketing services on our behalf.' Six months later, the lender wants to share customer data with a new telemarketing firm for a different type of marketing campaign. Under GLBA, what must the lender do?

Correct Answer

C) Nothing additional, as this falls within the disclosed category

Under GLBA, if the privacy notice adequately describes the categories of third parties with whom information may be shared (such as 'companies that perform marketing services'), the institution can share with new companies within those categories without additional notice, provided the sharing practices remain consistent with the disclosed categories.

Answer Options
A
Send a new privacy notice because this is a new company
B
Obtain specific consent because telemarketing wasn't mentioned
C
Nothing additional, as this falls within the disclosed category
D
Wait until the annual privacy notice update to disclose this relationship

Why This Is the Correct Answer

Under GLBA, if the privacy notice adequately describes the categories of third parties with whom information may be shared (such as 'companies that perform marketing services'), the institution can share with new companies within those categories without additional notice, provided the sharing practices remain consistent with the disclosed categories.

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