Page 33 - Microsoft Word - NEW 2017 Standard Program.docx

GRAMM-LEACH-BLILEY ACT (GLBA)

Commentary
This federal law provides the parameters for the protection and disclosure of Nonpublic
Personal Information (NPPI) to nonaffiliated third parties by financial institutions.

Recovery Agents and Recovery Agency owners are direct representatives of the lending
institutions they service, and are therefore subject to the requirements of this federal law.
Also, as representatives of our lender clients, we are not considered to be nonaffiliated third
parties. As you may be aware, especially when you are searching (skip-tracing) for a debtor,
you need all the information you can obtain from the lender, including certain NPPI. It is
imperative that you remember that when you are involved in any aspect of the
repossession process, including skip-tracing, you cannot divulge this NPPI to a
nonaffiliated third party.

NPPI is information that cannot usually be accessed by the general public. Although some
of this information might be defined as “public Information”, some of it is not “Publicly
Available.” The list of NPPI includes, but is not limited to:

Social Security Numbers
Dates of Birth
Unlisted Telephone Numbers
Driver License Numbers
Names of Relatives or References
Addresses
Vehicle Information
Child Support Information
Income Information
Insurance Information
Employment Information
Health Information
Bankruptcy Information
Taxpayer Identification Number

Financial Information such as:
Original Balances
Payment Amounts
Past Due Amounts

Account Numbers relating to financial transactions including:
Checking and Savings Accounts
Credit and Debit Cards
Loan Account Numbers

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