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Protection of NPI
The protection of Non-public Personal Information (NPI) has been the focus of recent mortgage regulations.
What is NPI (Non-Public Information)?
A. Any information that in itself or as part of a unique combination of information specifically recognizes an individual by unique descriptors and/or identifiers
B. Information from customers on forms, applications, or information about a customer’s transactions
C. Information about a customer which is otherwise unavailable to the general public
NPI includes first name or first initial and last name, coupled with social security number, driver’s license number, state-issued I.D. number, credit card number or other financial account numbers (found on personal checks). Examples are as follows:
A. Banking information, loan payoff, and credit card statements
B. Earnest money checks
C. Insurance, retirement, and tax statements
D. Social security numbers, dates of birth, and driver’s license copies
E. Private real estate title related items (Schedule A with purchase price and/or loan amount; remainder does not contain NPI), sales price commission amounts, and loan fees
We Are Committed to the Privacy of Your Information.
The protection of Non-public Personal Information (NPI) has been the focus of recent mortgage regulations and we would like to explain what NPI is and how we protect NPI.
To stay compliant, our process is to send the NPI to the borrower only. As an agent for the borrower, we will advise you that the information has been sent to the client. The client can decide whether or not to forward the information to you. Until we get clarification from the CFPB that the waivers these clients are signing (like the form put out by TAR) are acceptable, we are not relying on those to release us from liability under CFPB.
At closing, we will provide your client with a couple copies of the Closing Disclosure (or make an extra copy after all parties have signed) and if the buyer would like to share this with you, they can.
For the Seller’s agent, we will be able to send the Seller’s side of the Closing Disclosure directly to the agent as it does not contain any NPI about the borrower.