Privacy & Customer Account Numbers

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Question:

I received the ABA Bank Compliance magazine with an article about releasing account numbers. It stated "in a joint interpretive letter, the agencies reiterated that the GLB prohibits financial institutions from disclosing unencryptedcustomer account numbers to a nonaffiliated party, even with the customer's consent". How does this affect completing credit requests from mortgage companies, bankruptcy proof of claims and such?

Answer:

My understanding is that the prohibition against the release of customer account numbers is limited to releasing such numbers "for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer". The very legitimate purposes about which you inquire, of course, do not appear to constitute marketing and thus would seem to fall outside the prohibition.

First published on BankersOnline.com 8/6/01