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Personally Identifiable Information

August 24, 2023 QUESTION We passed our information security review by our banking department. However, they found that our description of personally identifiable information was too narrow.  We need to revise our policies and procedures and submit them to the banking department. Hopefully, you can offer a broader understanding of this area of customer privacy.   What is a good working description of personally identifiable information for our policy? ANSWER Most people have heard of nonpublic personal information, called “NPI.” To be precise, as it relates to financial institutions, NPI is personally identifiable information (“PII”) that:   1.    The consumer provides to a financial institution; 2.    Results from a transaction or service provided for the consumer; or 3.    The financial institution otherwise obtains, and that is not publicly available.  As a practical matter, most information that a financial institution collects from a consumer or customer is NPI. In fact, NPI also includes lists, descriptions or groupings of consumers, even if the data is publicly available, if the financial institution has derived the data from an individual’s nonpublic personal information.  COMPLIANCE TUNE-UP CMS TUNE-UP COMPLIANCE MANAGEMENT SYSTEM

Jonathan Foxx, Ph.D., MBA Chairman & Managing Director CONTACT US Compliance Solutions Cost-Effective Quality Control Pioneers in the Mini-Audit Policies & Procedures

Did You Know? What are the primary criteria for selecting an appraiser from a pre-approved appraiser list or panel? COMPLIANCE SOLUTIONS Any employees of the lender tasked with selecting appraisers for the appraiser list are independent of the loan production staff; The loan production staff is not involved in selecting an appraiser off the list for a particular appraisal assignment.  AIR TUNE-UP

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