Atlantic Coast Mortgage Group, Inc. (ACMGI) does not share non-public borrower information with affiliates or non-affiliates, except to those entities that are on a "need to know" basis in the normal course of business (i.e. investors, credit bureaus, government agencies, MI Companies, third party underwriters, etc.). ACMGI's complete privacy policy statement is as follows:
Atlantic Coast Mortgage Group, Inc. - Privacy Policy
In compliance with the GRAMM-LEACH-BLILEY ACT - FINANCIAL MODERNIZATION Report on Title V - Privacy and Restrictions on Disclosing Non-Public Personal Information
DISCLOSURE OF NONPUBLIC PERSONAL INFORMATION - GENERAL PURPOSE
In compliance with Title V of the Financial Modernization Act, ACMGI has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customer's non-public personal information, as that term is defined in the Act. The FTC is the regulatory body governing non-depository institutions (mortgage bankers) relative to the Act. ACMGI's Privacy Policy has been written in compliance with the requirements of the Act, which has the purpose of:
ensuring the security and confidentiality of customer records and information;
protecting against any anticipated threats or hazards to the security or integrity of such records; and
protecting against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any customer.
PRIVACY POLICY
ACMGI will not, directly, or through its affiliates, disclose to a nonaffiliated third party any non-public personal information without first, providing notice to the customer and affording them the opportunity to "opt out" of the sharing agreement.
ACMGI's current policy is NOT to share any non-public personal information with any nonaffiliated third party except as necessary for the express intention of processing and closing of a borrower's loan application and the servicing and selling of a borrower's loan. This generally includes obtaining information from credit agencies, verification of assets, income, or employment or sharing information with third party service providers for hazard, flood or private mortgage insurance coverage, servicing, auditing and enforcement of the Note and the Mortgage.
At this time, the "opt out" provision is not applicable due to our policy of NOT sharing any non-public personal information with any nonaffiliated third party except for the purposes indicated above. The definition of non-personal public information includes not only privately obtained borrower information such as social security numbers, credit histories, depository and income and employment information but also includes customer lists which include loan numbers and other non-public data.
No employee of ACMGI is authorized to share any borrowers non-public personal information for the purpose of solicitation for additional products or services or any other purpose.
SECURITY AND CONFIDENTIALITY
Only those employees whose specific job duties require access to the borrower's loan files and therefore their non-public personal information may be in possession of any loan file. Managers are to ensure that there is no unauthorized access of loan files in their branch offices.
Atlantic Coast Mortgage Group, Inc.'s employees are given the following notice:
Privacy Protections for Customers to Thwart Fraudulent Access to Financial Information
Title V. Subpart B provides the following, "Fraudulent Access to Financial Information" established a general rule prohibiting persons from obtaining or attempting to obtain, or disclosing or attempting to disclose to any person, a financial institution's "customer information" by any means of false pretenses. Anyone who knowingly and intentionally violates Section 521 is subject to fines and imprisonment or both.
The scope of "false pretenses" encompasses the following activities:
Making a false, fictitious or fraudulent statement or representation to an officer, employee or agent of a financial institution;
Making a false, fictitious or fraudulent statement or representation to a customer of a financial institution; and
Providing any documentation to an officer, employee or agent of a financial institution, knowing that the document is forged, counterfeit, lost, stolen, was fraudulently obtained or contains a false, fictitious or fraudulent statement or representation.
Storage of Loan Files
Closed or cancelled loan files are to be maintained in a secured storage location.
Destruction of Loan Files
When loan files are eligible to be destroyed due to loan payoff (and after the applicable regulatory agency-required retention period has expired), loan files are to be shredded and NOT just discarded.
Third Party Service Providers
All third party service providers must sign a confidentiality agreement or clause as part of its agreement with ACMGI that acknowledges their compliance with ACMGI's Privacy Policy.
Employee Education
All employees are required to read the ACMGI Privacy Policy and acknowledge the receipt of said policy. Signed acknowledgements shall be maintained in the employees personnel file.
Employees who violate all or any portion of this Privacy Policy are subject to immediate termination.
PRIVACY POLICY STATEMENT
Initial Disclosure:
The ACMGI Privacy Policy shall be provided to borrowers as follows:
Retail Loan Originations:
The "Interviewer" in the loan application process must give this Privacy Policy Statement to the borrower to be executed at the time loan application is taken face-to-face. A copy must be given to the borrower for their records and a copy retained at the branch and a copy must also be available for the underwriter.
If the loan application is taken by phone or by mail, this Privacy Policy Statement is to be mailed to the borrower with the Initial Truth-in-Lending Disclosure and other origination disclosures. A copy is to be retained in the branch and a copy must be made available to the underwriter. The cover letter that is sent with the origination disclosure(s) must reflect the inclusion of this document.
Wholesale Loan Originations:
The Privacy Policy Statement is to be mailed to the borrower with the Initial Truth-in-Lending Disclosure and other applicable origination disclosures. A copy is to be retained in the loan file.
|
