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Exam CRCM topic 1 question 214 discussion

Actual exam question from ABA's CRCM
Question #: 214
Topic #: 1
[All CRCM Questions]

Initial privacy notice-12CFR332.4; 12CFR40.4; 12 CFR 216.4; 12 CFR 573.4 says that:

  • A. A notice must be given to a consumer before the institution discloses any nonpublic personal information about the consumer to a nonaffiliated third party, unless the disclosure is on the exempt list
  • B. A notice is not required to be given to a consumer who is not a customer if the financial institution does not disclose any nonpublic personal information about the consumer to any nonaffiliated third party, other than as authorized by this regulation
  • C. Only one notice is required to be provided on joint accounts. Therefore only one notice need to be provided to consumer loan customers even if there is more than one borrower and even if there is a separate guarantor
  • D. All of these
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Suggested Answer: D 🗳️

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Cam22
4 months ago
Selected Answer: D
There aren't questions like this on the exam. The correct answer is D. All of these. Each statement reflects different aspects of the requirements for initial privacy notices under Regulation P, which implements the privacy provisions of the Gramm-Leach-Bliley Act (GLBA) across various regulatory authorities (as indicated by the different CFR citations for banks, savings associations, and other financial institutions). These aspects include the necessity of providing a privacy notice before disclosing nonpublic personal information to nonaffiliated third parties (unless exempt), the conditions under which a notice is not required for non-customers, and the protocol for issuing notices for joint accounts or loans with multiple borrowers or guarantors.
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