Answer:
As a point of clarification, Regulation P implements the Gramm Leach Bliley Act relating to sharing of information for marketing purposes. The Right to Financial Privacy Act relates to sharing information in response to government requests for information such as an IRS Summons or subpoenas for records.
When a consumer applies for federal assistance such as the Federal Assisted Housing Program, they should be signing a form granting release of information and that signed form should accompany the verification of deposit request.
Government requests for information requiring a Certificate of Compliance from the government agency would be for reasons where the consumer had not previously granted consent for release of information (such as the aforementioned summons or subpoena.) If you are not sure of the legal ramifications of document that is requesting disclosure of information, confer with bank counsel before providing any information.
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