Yes. The IDFPR has clarified in an interpretive letter that any privacy exceptions that apply under federal law also apply under Illinois law. The joint marketing exception is located in Subpart C of the federal regulations (12 CFR 1016.13), and “a state bank need not obtain a customer’s authorization to make disclosures permitted by one of the exceptions contained in Subpart C of the federal regulations.” Interpretive Letter 01-01 (March 9, 2001).
Can we share customer information under the joint marketing exception in the federal privacy rules, even though Illinois law does not include the same exception?
—
by