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Is the bank required to send a revised privacy notice to customers who have asked that the bank not mail anything (Do Not Mail), to customers in bankruptcy, to customers with foreign addresses, or to customers who are deceased?

My bank has revised is privacy notice, so the bank will be required to send it to our customers this year. My question is whether the bank is required to send the annual notice to customers who have asked that the bank not mail anything (Do Not Mail), to customers in bankruptcy, to customers with foreign addresses, or to customers who are deceased?

The bank is not required to mail annual privacy notices to customers who have requested that the bank not mail notices. Customers who have declared bankruptcy are still customers who must receive the annual notice. Similarly, banks must send annual notices to customers with foreign addresses. For deceased customers, the answer depends. The personal representative of the deceased “stands in the shoes” of the deceased, so should receive the notice. However, no annual notice is required for accounts opened for the deceased’s estate, since the estate is not an individual. (October 2019)

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