[kmeade]

Example: A bank purchases a mailing list from a non-affiliated third-party, NOT a Credit Reporting Agency for marketing purposes. The mailing list would be based on the geographic area around the bank’s location. Sometimes the third party may mail general bank promo information, and sometimes the bank may use the list to send information. Would this trigger any concerns, and what regulations would affect this type of arrangement?
The bank would not be giving any consumer information, only receiving data and processing services of stuffing and mailing information to a list provided by the third party.

Topic

[jholzknecht]

I don’t see any obvious problems. My concerns would be greater if you were making phone calls or sending emails.

You mention that the list includes “geographic area around the bank’s location.” Please assure the list includes all geographic areas, including low- and moderate-income areas, and areas with significant minority population. Examiners would likely want to know what criteria were provided to the third-party upon which the list selection was based.

[kmeade]

To clarify, the situation described above would not trigger concerns with the Bank’s privacy notice (do not share) or the FCRA opt-in/opt-out requirement?

[jholzknecht]

Based on your assertion that information is not shared with the third party, there is no privacy issue. You also indicated that the third party is not an affiliate, so the FCRA affiliate sharing rules would not apply.

[Author]

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