One depositor, A, has two different joint accounts, one with X and the other with Y. When annual or revised notices are required as to both accounts, how many notices must I provide?
A. Annual and revised notices pertaining to each of the joint accounts may be provided either to A or to both of the other account holders respectively (unless one or more requests separate notices). Thus, one notice to A is sufficient, as long as the notice is accurate as to both accounts. 313.9(g). The Privacy Rule does not require you to mail two identical notices to A, one for each account. However, you must neither disclose to X that A has a joint account with Y nor disclose to Y that A has a joint account with X, unless these facts are publicly available. The fact that a consumer is a financial institution’s customer is nonpublic personal information, unless you have a reasonable basis to believe that the customer relationship is a matter of public record.
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