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Are we required to truncate loan account numbers on loan statements and notices, such as past due notices or right to cure notices, that are sent to the customer? – IBA Compliance Connection

Are we required to truncate loan account numbers on loan statements and notices, such as past due notices or right to cure notices, that are sent to the customer?

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No, you are not required to truncate loan account numbers on statements or notices sent to customers. Both Illinois and federal law require truncation of credit card and debit card account numbers on receipts, but we are not aware of any law or rule that would apply this requirement to loan account numbers and other documents. However, you may want to consider the practice of truncating loan account numbers on these documents, since it would add a layer of protection when mailing them to customers, since there is always a chance that a mailed statement or notice could be lost or misdirected to a third party.

For resources related to our guidance, please see:

  • Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/2NN, prohibition on printing full credit and debit card account number and expiration date
  • FACTA, 15 USC 1681c(g), requires truncation of credit card and debit card numbers