Three Things Creditors Need to Know about Email Addresses, Agencies, and Compliance Risk

Editor's Note: This article was initially published in the January 20, 2021 edition of the iA Strategy & Tech Newsletter, and is a collaboration between Erin Kerr, Director of Content for iA Strategy & Tech, and Colene McNinch Partner and the Chief Compliance Officer at M&G Solutions

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Most creditors obtain consumers’ email addresses when a loan or line of credit originates and, of course, agencies typically want those consumer email addresses from creditors. It makes sense that creditors would pass the email data to their agency partners when accounts are placed.

But wait! It’s not that simple. 

When creditors pass along email data, they actually have a tough decision to make: follow the procedure outlined in Regulation F for providing email addresses to agency partners, or simply rely on their agency partners willingness and ability to implement processes that comply with section 6(d)(4)(i) of Regulation F? 

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