We are concerned about and respect the privacy of our customers’ personal financial information. We understand that our customers furnish sensitive information to us in the course of daily business, and we are committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.
TYPES OF INFORMATION THE LENDER COLLECTS:
We collect nonpublic personal information from many sources. We collect nonpublic personal information directly from consumers on various applications and forms, for example, loan applications, and requests for information about products and services.
We collect information as a result of transactions between us and our customers and as a result of providing a product or service to our customers. This includes transaction information from other loans between us and our customers.
We collect information from credit reporting agencies.
Nonpublic personal information does not include that which we obtain from government records, widely distributed media, or government-mandated disclosures.
TYPES OF INFORMATION THE LENDER DISCLOSES:
We do not disclose any nonpublic personal financial information about our current or former customers to nonaffiliated third parties except as permitted by law. We may disclose certain personally identifiable information without allowing consumers the right to opt out of our sharing agreements in the following circumstances;
- To certain non-affiliated third parties (under limited circumstances) to the extent permissible under law to service the account, report to credit bureaus, manage risk, and perform other financial services related activities.
- To disclose information that we receive on a customer’s loan application such as the customer’s assets, liabilities, income, and employment history in order to determine whether a loan made to the customer is salable in the secondary market, for example.
- To disclose information necessary to enforce our legal or contractual rights or the right of any other person who is engaged in the financial transaction.
- To disclose information required in the ordinary course of business, such as in the settlement of claims or benefits or the confirmation of information to the consumer or the consumer’s agent.
- To provide information to agencies, persons that are assessing our compliance with industry standards, and our attorneys, accountants, and auditors.
- To the extent permissible under the Right to Financial Privacy Act.
- To a consumer reporting agency under the Fair Credit Reporting Act.
- To comply with federal, state, or local laws, rules, and other applicable legal requirements.
SAFEGUARDING CUSTOMER INFORMATION:
We protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. We have appointed our compliance officer as the financial privacy coordinator, who is responsible for maintaining internal procedures to ensure that our customers’ information is protected. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations departments.
If we change our policy or practice by, for example, adding a category of information that will be disclosed to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.