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Under the Rule, a "consumer" is someone who obtains or has obtained a financial product or service from a financial institution that is to be used primarily for personal, family, or household purposes, or that person's legal representative.
The term "consumer" does not apply to commercial clients, like sole proprietorships.
Second, how often does the business engage in a financial activity?
The regulations required all covered businesses to be in full compliance by July 1, 2001. The law covers a broad range of financial institutions, including many companies not traditionally considered to be financial institutions because they engage in certain "financial activities." Financial institutions must notify their customers about their information-sharing practices and tell consumers of their right to "opt-out" if they don't want their information shared with certain nonaffiliated third parties.
Financial institutions covered by the Gramm-Leach-Bliley Act must tell their customers about their information-sharing practices and explain to customers their right to "opt out" if they don't want their information shared with certain third parties.
Is your company following the requirements of the Privacy Rule?
Your activities determine whether you are a "financial institution" under the Privacy Rule.
According to the Bank Holding Company Act provision and regulations established by the Federal Reserve Board, "financial activities" include: These examples are taken from the section 4(k) provisions and regulations on financial activities.
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A financial institution establishes a customer relationship with an individual when it originates a loan.