Continuing Education Course 11 - The Gramm-Leach-Bliley Act (GLBA) on 3rd Party Disclosure of Nonpublic Personal Information (NPPI) and Social Media
The Gramm-Leach-Bliley Act (GLBA) provides the parameters for the protection of Nonpublic Personal Information (NPPI) to nonaffiliated third parties by financial institutions.
Recovery Agency owners and Recovery Agents are direct representatives of the lending institutions they service, and are therefore subject to the requirements of this federal law.
As representatives of our lender clients, we are not considered to be nonaffiliated third parties.
As you should be aware, especially when you are searching (skip-tracing) for a debtor, you need all the information you can obtain from the lender, including certain NPPI.
It is imperative that you remember that when you are involved in any aspect of the repossession process, including skip-tracing, you cannot disclose this NPPI to a nonaffiliated third party.