REPUBLIC MORTGAGE INSURANCE COMPANY
[Statement of Policy Concerning Privacy of Consumer Information]
Effective/January 1, 2001
Republic Mortgage Insurance Company (RMIC) has prepared this Statement of Policy to explain in detail its firm corporate commitment to appropriate standards for handling consumer information.
RMIC receives, processes and holds a great deal of personal financial information relating to individual consumers whose mortgage loans RMIC insures. This information includes mortgage loan application information, credit reports, and other sensitive information generated in connection with the mortgage insurance application process. RMIC is respectful of consumers’ expectations of privacy in the treatment of this information and mindful of its own business partners’ needs to assure themselves that consumer information they provide to RMIC will be treated appropriately. This Statement of Policy applies to all consumer information RMIC obtains in connection with this mortgage insurance business.
COMPLIANCE WITH THE LAW
RMIC complies with all federal and state privacy-related laws, including the Gramm-Leach-Bliley Act (GLB), the Fair Credit Reporting Act (FCRA), and state insurance regulations concerning the privacy and security of consumer information.
LIMITATIONS ON SHARING INFORMATION
RMIC does not currently share any consumer information with affiliates or nonaffiliated third parties in ways that require or will require the delivery of notices to consumers. RMIC does not share "consumer report information" other than "transaction/experience" information with its "affiliates" as those terms are defined by FCRA. RMIC does not share "nonpublic personal information" with nonaffiliated third parties except pursuant to statutory or regulatory exceptions to GLB’s notice and opt-out requirements.
REQUIREMENTS FOR THIRD PARTIES TO RECEIVE CONSUMER INFORMATION
If and when RMIC does share consumer information with an affiliate or nonaffiliated third party pursuant to the above limits, RMIC will only do so if the third party that receives the consumer information agrees to protect the information with an information security program no less effective than RMIC’s. In addition, a nonaffiliated third party receiving consumer information must agree to use that information only in connection with the performance of services for RMIC, and must agree not to redisclose that information.
ADDITIONAL LIMITATIONS IMPOSED BY LENDERS
With regard to consumer information that RMIC has received from a lender, RMIC will respect any restrictions or limitations regarding the sharing of such information imposed by the lender at the time the information was supplied. These restrictions or limitations are in addition to RMIC’s own self-imposed limitations on information sharing.
CHANGES IN POLICY
If RMIC changes its information-sharing practices, it will do so only after providing all notices to consumers required by applicable law and regulations.
INFORMATION SECURITY PRACTICES
RMIC has an information security program to protect consumer information. RMIC will continually monitor and, if necessary, upgrade its information security program to respond to new security threats and new regulatory requirements.