Topping this discussion as there seems to be some lack of understanding regarding the above, or that perhaps Mr. GLBA actually retired, or was put out to pasture by some not so noble-minded group of NSAs, mobile closures, notary do-wellers or whatever one might want to be called, only the Shadow knows for sure.
Back to basics:
First, yes GLBA is very much alive and as many other laws has succumbed to the CFPB Mother ship.
Second, any person not considered an affiliated third party is considered 'general public' by the GLBA and the CFPB.
Third, in the wisdom of the CFPB, it's founding fathers tagged the lender to supervise affiliated third parties: Escrow/Title companies, and by 'extension', per the April, 2012 CFPB Bulletin, such people as notary loan closers.
Fourth, an often overlooked, or passed by set of documents in the loan package is a set of the Lender's Privacy Policy explaing Mr. GLBA while Mr/Ms Shadower just might be ironically following and looking along.
Lastly, brokers for the Lender's are often required to insert their own Privacy Policy, along with the Lender's, as that's just how unimportant the whole idea is. ( yes, being sarcastic here).
I am tempted at this point to pull out the Broker Privacy Policy that I so imperfectly wrote, and add that we reserve the right to disclose non-public private information to non-affiliated general public if they so happen to be riding in the same car as the mobile closer, and happened to step inside to get their feet warm.
http://www.mortgagecompliancemagazine.com/weekly-newsline/privacy-and-confidentiality/
Good Day!
PS - I might join The Secret Society but I don't think my secret decoder ring would go over so well.
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