Annual Privacy Notices for Former Customers | Compliance Manager Exam | ABA

Annual Privacy Notices for Former Customers

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Question

Annual privacy notices are not required to be given to former customers, including cases where:

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Explanations

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A. B. C. D.

BC

The annual privacy notice is a disclosure that financial institutions are required to provide to customers under certain circumstances. The notice must explain the institution's policies and practices with respect to the collection, use, and sharing of nonpublic personal information (NPI), such as customer name, address, social security number, account numbers, etc.

According to the Gramm-Leach-Bliley Act (GLBA), financial institutions must provide the annual privacy notice to customers at least once per year, even if the customer relationship is terminated. However, there are some exceptions to this requirement.

Option B, which states that the customer pays off the loan or the institution charges it off, is correct. Once the customer has paid off the loan or the institution has charged it off, the customer relationship is terminated, and the annual privacy notice is no longer required.

Option A, which states that a deposit account is active, is incorrect. The GLBA does not make an exception for active deposit accounts, and the annual privacy notice is still required.

Option C, which states that the institution no longer provides any open-end statements or notices to the customer, is also incorrect. The GLBA does not make an exception for institutions that do not provide open-end statements or notices, and the annual privacy notice is still required.

Therefore, the correct answer is B, "A customer pays a loan in full or institution charges off the loan."