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?

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).