Of course you can keep records of your activities in any form you desire. BUT, if you are required to keep a journal, then that journal MUST reflect the necessary elements as dictated by your state laws. Also, for those who keep copies of documents associated with the loan, be aware of GLB. ( http://www.ftc.gov/privacy/glbact ) If you don't work for a bank, brokerage or other financial institution, chances are you heard briefly about GLB and decided that it didn't apply to you.
Think again! The Federal Trade Commission uses an extremely broad definition of the term "financial institution" for the purposes of GLB compliance. In fact, almost any organization that works with people's money is considered a financial institution. Some inclusions are obvious – nobody would question whether a bank, credit union or brokerage would need to comply with GLB. However, there are many less obvious inclusions as well. Some examples from the FTC include:
* Preparers of income tax returns
* Consumer credit reporting agencies and credit counseling services
* Real estate transaction settlement services
* Debt collection agencies
In addition to the direct providers of those services, any organization that receives data from those providers must also comply with GLB requirements. |
