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A mortgage company shares borrower data with three entities: (1) an affiliated title insurance company, (2) an unaffiliated credit bureau for routine underwriting, and (3) an unaffiliated direct mail marketing company. Under GLBA, which sharing arrangement requires the company to provide customers with an opt-out opportunity before sharing?

Federal Mortgage Law · 24% of the SAFE exammedium

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Correct answer: Only sharing with the unaffiliated direct mail marketing company requires an opt-out opportunity

Under GLBA's Regulation P: (1) Sharing with affiliates must be disclosed in the institution's privacy notice, but does not automatically trigger the same consumer opt-out right as unaffiliated third-party sharing. (2) Sharing nonpublic personal information with an unaffiliated credit bureau for routine underwriting and loan processing falls under GLBA's 'processing and servicing' exception — this is an operational necessity exempt from the opt-out requirement. (3) Sharing customer data with an unaffiliated direct mail marketing company for marketing purposes is NOT an operational exception — this sharing requires the company to provide customers with a clear notice and a reasonable means to opt out before the sharing occurs. "," overstates the requirements — not all sharing triggers opt-out rights. "s operational exceptions" incorrectly treats the credit bureau (operational exception) the same as the marketing company (no exception). "All three arrangements require opt-out notice before..." incorrectly classifies marketing data sharing as an operational exception when it is not.

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