Lisa, a licensed insurance producer, provides an auto insurance quote to Mark, but Mark decides not to purchase the policy. Later that week, Lisa sells a homeowners policy to Sarah, who maintains her active policy and pays her premiums through Lisa's agency. Under the Gramm-Leach-Bliley Act (GLBA), which of these individuals is legally required to receive an annual privacy notice from the agency?
- Only Sarah, because she has established an ongoing customer relationship with the agency.Cevap
- BBoth Mark and Sarah, because anyone who provides nonpublic personal information must receive an annual notice.
- COnly Mark, because his personal information was collected without a finalized insurance contract.
- DNeither individual, because the GLBA privacy requirements only apply to federal banks, not state-licensed insurance agencies.
Cevap
Only Sarah, because she has established an ongoing customer relationship with the agency.
The correct answer accurately applies the GLBA's distinction between a consumer and a customer. A 'consumer' is someone who has an isolated transaction with a financial institution, such as requesting a quote. A 'customer' is a consumer who establishes an ongoing relationship, such as purchasing and maintaining an insurance policy. The GLBA requires financial institutions to provide an initial and an annual privacy notice to customers, but not to consumers.
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Anahtar Kavram
GLBA Consumer vs. Customer Definitions and Notice Requirements