Consumer Protection
2001 Letters
- May 25, 2001
- Joint interpretation issued by the Legal Divisions of the Board, the OCC, the FDIC, the OTS and the NCUA responding to a request that financial institutions be allowed to disclose unencrypted account numbers to an insurance company. The agencies responded that section 502(d) of the Gramm-Leach Bliley Act, as implemented by Regulation P, 12 CFR 216.12, is not subject to the exception for disclosing information with the consent or at the direction of the consumer. The agencies also determined that interpreting the Act to consider marketing to have ended at the time the customer accepts the product would substantially undermine the prohibition, effectively limiting its application to the sharing of account numbers for tracking purposes while not denying third party marketers access to customer accounts.