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Before the team acts on a branch training session, the supervisor must address GLBA Privacy Requirements. Which response is most defensible?

Correct Answer

C) Verify identity before discussing loan information

Why this is correct: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to protect the privacy and security of customers' nonpublic personal information. A key safeguard is ensuring that loan information is only shared with the borrower or their authorized representative. Therefore, before discussing sensitive loan details, the most defensible action is to "Verify identity before discussing loan information" to prevent unauthorized disclosure. Why the other choices are wrong: "Treat the GLBA Privacy Requirements review as complete because the file contains a related licensing note" is wrong because a note about a different topic (licensing) does not fulfill the specific requirement to protect privacy. "Ignore the consumer-protection issue unless the borrower complains" is wrong because GLBA imposes proactive obligations, not reactive ones based on complaints. "Document the issue later instead of correcting the compliance problem first" is wrong because a privacy breach must be prevented immediately; documenting it later does not correct the violation. Exam tip: GLBA's Privacy Rule is about safeguarding information. The core action is always to confirm authority before sharing any nonpublic personal information.

Answer Options
A
Treat the GLBA Privacy Requirements review as complete because the file contains a related licensing note.
B
Ignore the consumer-protection issue unless the borrower complains.
C
Verify identity before discussing loan information
D
Document the issue later instead of correcting the compliance problem first.

Why This Is the Correct Answer

The correct response is "Verify identity before discussing loan information" because Borrower information must be protected and shared only with authority.

Why the Other Options Are Wrong

Option A: Treat the GLBA Privacy Requirements review as complete because the file contains a related licensing note.

This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.

Option B: Ignore the consumer-protection issue unless the borrower complains.

Ignore the consumer-protection issue unless the borrower complains. is not correct because it does not apply the rule tested by this file scenario.

Option D: Document the issue later instead of correcting the compliance problem first.

Document the issue later instead of correcting the compliance problem first. is not correct because it does not apply the rule tested by this file scenario.

Memory Technique

borrower privacy and confidentiality: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.

Exam Tip

Match the file facts to borrower privacy and confidentiality; do not choose an exception or shortcut that skips the required rule.

Common Mistakes to Avoid

  • -Choosing an internal exception instead of the governing rule
  • -Treating preliminary or informal facts as a substitute for required documentation
  • -Answering from a familiar but unrelated mortgage topic
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