We do not believe that sharing limited information about the seller in the Closing Disclosure for a consumer mortgage transaction will create any privacy issues, primarily for two reasons.

First, the financial privacy protections under state and federal law apply only to a customer who has obtained a financial product or service from you. Because the seller in a transaction is not your customer, the high levels of privacy protections for personal financial information should not apply here. Second, since the seller’s information in the Closing Disclosure necessarily would have been provided by the seller, it seems reasonable to assume that the seller consented to its disclosure.

For resources related to our guidance, please see:

• Regulation P, 12 CFR 1016.3(e)(1) (“Consumer means an individual who obtains or has obtained a financial product or service from you that is to be used primarily for personal, family, or household purposes, or that individual’s legal representative.”)

• Regulation P, 12 CFR 1016.15(a)(1) (“Exceptions to opt out requirements . . . . (1) With the consent or at the direction of the consumer, provided that the consumer has not revoked the consent or direction.”)

• Illinois Banking Act, 215 ILCS 5/48.1(c) (“Except as otherwise provided by this Act, a bank may not disclose to any person, except to the customer or his duly authorized agent, any financial records or financial information obtained from financial records relating to that customer of that bank unless . . . .”)