Regulation P and Sharing Information Under a Joint Marketing Agreement
Issue/Inquiry
The Bank has a joint marketing agreement with a credit card company, which issues credit cards in the Bank’s name but performs the underwriting and makes the credit decision. The company has requested a list of customer names, addresses, and social security numbers, so that they can run a credit search and decide on what card to offer a customer. The Bank’s Privacy Policy allows it to share personal information for joint marketing with other financial companies. Would the Bank be permitted to provide this customer information to the credit card company?
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