"I have wanted to point out that maybe as long as an NSA disclosed on her website AND presented her own privacy policy up front, it might be okay.
The NSA would need to declare that she took in ride-alongs and that some of the information might be shared with non-affiliated shadows furtively or overtly, accidentally or purposefully.
But, I could not figure out how to work in the opt-out"
That's easier than one may think. Just copy the passage from your local Traffic Laws that says the speed limit is 'X' and that we have opted out to drive at whatever speed we choose. See how that goes.
And so it goes with trying to opt out what the lender, the CFPB and the GLBA have 'opted in', or in some circles called 'the law', a Federal Act at that.
Title and Escrow Privacy Policies must at the very least match and cover the Privacy Polices of lenders that supervise them. The lender may request to see these Policies, just as they do the Broker's Privacy Policies.
So it's as simple as that. Since by extension of working for the escrow's closing department the NSA is under the supervision of the lender, all the NSA needs to do is have the lender approve one's opting out of GLBA. Then watch for red flashing lights and sirens.
There is no such thing as an NSA Privacy Policy, anymore than there is such as thing as a NSA set of Traffic Laws.
Moral: Don't sign while intoxicated.
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