Risk If Privacy Notice Is Not Sent to Client

Answered by:

Question:

Who owns the risk if an annual Privacy Notice was not sent to a client, the lender or the servicer?

Answer:

My initial thought is "yes." But the owner of the account is the one, I believe, who has the disclosure responsibility and has a contractual relationship with the servicer. That said, ensure you look at the Top Stories on BOL. The annual notice requirement will be easing for many based on the FAST Act signed Dec. 4, 2015 by the President.