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Fast Loan Processing 's PRIVACY POLICY
In compliance of :
THE GRAMM-LEACH-BLILEY ACT - FINANCIAL MODERNIZATION
Report on Title V - Privacy and Restrictions on Disclosing
Nonpublic Personal Information
DISCLOSURE OF NONPUBLIC PERSONAL
INFORMATION - GENERAL PURPPOSE
In compliance with Title V of The Financial Modernization
Act, Fast Loan Processing has an affirmative and continuing
obligation to respect the privacy of its customers
and to protect the security and confidentiality of
those customers' nonpublic personal information, as
that term is defined. The Federal Trade Commission
is the regulatory body governing non-depository institutions
(mortgage bankers) relative to this Act. Fast Loan Processing's Privacy Policy has been drafted in compliance
with the requirements of this 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
Fast Loan Processing will not, directly or through
its affiliates, disclose to a nonaffiliated third
party any nonpublic personal information without first
providing notice to the consumer and affording them
the opportunity to "opt out" of the sharing
arrangement.
Fast Loan Processing's current policy is NOT to share any non-public
personal information with any nonaffiliated third
party source 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 the hazard, flood or private
mortgage insurance coverage, servicing, auditing and
enforcement of the Note and Deed of Trust.
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 is authorized to share any borrower's
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 borrowers' loan
files and therefore their non-public personal
information may be in possession of any loan file.
We are to ensure there is no unauthorized access
of loan files in our office.
Fast Loan Processing employees are given this notice:
Privacy Protections for Customers to Thwart Fraudulent
Access to Financial Information
Tittle V, Subpart B provisions addressing "Fraudulent
Access to Financial Information" established
a general rule prohibiting persons from obtaining
or attempting to obtain, or disclosing or attempting
to cause to be disclosed to any person, a financial
institution's "customer's information" by
any means of false pretenses. Anyone who knowingly
and intentionally violates Section 521 is subject
to fines, 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
- Third party service providers are required
to execute a Confidentiality Agreement or Clause
as part of its contract with Fast Loan Processing
in compliance with said Act. "Grandfathered"
contracts, those in effect as of July 1, 2000,
will be given until July 1, 2002 to comply with
said amendment.
Employee Education
- All employees are required to
read the Fast Loan Processing Privacy Policy and acknowledge receipt
of said policy. Acknowledgements to be maintained
in the employee's personnel file in Human Resources.
Employees who violate all or any portion of this
policy are subject to termination.
PRIVACY POLICY STATEMENT
Initial Disclosure:
The Fast Loan Processing's Privacy Policy Statement
is to be provided to the borrower commencing with
loan application received on or after July 1, 2001
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 the loan application is taken face-to-face.
A copy must be given to the borrower for their
records and a copy retained in the branch file
and a copy must be included in the credit package
upon submission to 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 applicable
origination disclosures. A copy is to be retained
in the branch file and a copy must be included
in the credit package upon submission to the underwriter.
The cover letter that is sent with the origination
disclosures 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 storage file.
Annual Disclosure:
- The Privacy Policy Statement is to be
re-disclosed (by mail) annually for those loans
Fast Loan Processing continues to service beyond
12 months from the loan closing date.
Website Security Policy:
"All information obtained through
this website follows our Privacy Policy and are encrypted
by SSL and 128-bit encryption. All measures are being
taken to ensure that your information remains secure
and confidential."
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