Revised April 28, 2015
Categories of NPI regularly collected from our consumers may include: 1.) Name and address; 2.) Social Security Number; 3.) Driver’s license number or other ID numbers; 4.) Loan or financial account numbers; 5.) Other information a consumer provides on a former application; 6.) Information about a consumer on a form, application or report obtained by a financial institution.
In compliance with the GLBA, we do not share NPI about a consumer with a non‐affiliated third party, unless allowed by law. Our privacy policies and practices regarding NPI of consumers and customers (as defined by GLBA) are as follows, subject to any exceptions as permitted by law:
- We protect NPI of customer(s) and consumer(s) by maintaining the physical security of files and documents within the office and network security of information when it is stored in an electronic format.
- We disclose NPI to our personnel and our affiliated underwriters, First American Title Insurance Company and/or Stewart Title Insurance Company.
- On a need‐to‐know basis only, we disclose NPI to non‐affiliated third parties under the following circumstances (exempt disclosures under GLBA Section 313.14 and 313.15):
- Disclosures necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes (see section 313.14(b)), and
- Disclosures made in connection with:
- Servicing or processing a closing or service that a consumer requests or authorizes
- Maintaining or servicing a consumer’s file
- With consumer consent
- To protect the confidentiality or security of records
- To protect against or prevent actual or potential fraud
- For required institutional risk control or for resolving consumer disputes or inquires
- To persons holding a legal or beneficial interest relating to the consumer
- To persons acting in a fiduciary or representative capacity on behalf of the consumer (i.e., the consumer’s attorney or agent)
- To provide information to insurance rate advisory organizations, persons assessing compliance with industry standards, the financial institution’s attorneys, accountants or auditors
- To law enforcement entities or self‐regulatory groups (to the extent permitted or required by law)
- To comply with Federal, State, or local laws o To comply with subpoena or other judicial process
- To respond to summons or other requests from authorized government authorities
- Pursuant to the Fair Credit Reporting Act, to a consumer reporting agency or from a consumer report reported by consumer reporting agency
- In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of a business or operating unit