Federal Mortgage Law · 24% of the SAFE exammedium
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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