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Hacking - Notice to Customers
Question: Some of our debit card customers' information was compromised in the latest hacking incident. Do we need to notify them?
Answer: Yes, if their name plus "sensitive" information (e.g. SSN, DL, card number) was acquired by the intruder. Texas law will directly address this effective 9/1/05. Meanwhile, the federal regulatory guidance indicates that the notice (which includes tips on protecting oneself) should be given if after an investigation the bank determines that the information has been or WILL BE misused. Here is a link to the guidance: http://www.federalreserve.gov/boarddocs/press/bcreg/2005/20050323/attachment.pdf Scroll down to page 62 for the requirements! It is hard to argue that an intruder doesn't intend mischief, so give the notice. Also, notify your regulator.
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Comments & Questions
If you would like
to comment on legislative topics or if you have questions about this
information please call our public affairs expert, Mae Beth Palone at
(800) 749-4228 or E-mail mbpalone@ibat.org.
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