Consumer complaint received 2023-12-21
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: NY
Product: Credit reporting or other personal consumer reports
Sub-product: Credit reporting
Issue: Problem with a company's investigation into an existing problem
Sub-issue: Investigation took more than 30 days

Complaint:
My credit report has shown i have XXXX late student loan payments during a government forbearance i was also a part of. They didn't send any communication of a late payment or missing payment and its reported wrong on all of my reports. Per the FCRA as a federally protected consumer i have the legal right to privacy and to OPT OUT of all communications and furnishings to 3rd party companies such as XXXX, Transunion, XXXX, XXXX XXXX  ETC. I have reported this several times sent letters emails called and reported through CFPB and the company continues to stall the process. The law states it is ILLEGAL to report transaction HISTORY! Check Facts Below. 

Find both laws Broken below in full detail. 

15 U.S. Code 1681- Congressional findings and statement of purpose Under Code : ( a ) Notice requirements Except as otherwise provided in this subchapter, a financial institution may not, directly or through any affiliate, disclose to a nonaffiliated third party any nonpublic personal information, unless such financial institution provides or has provided to the consumer a notice that complies with section 6803 of this title.

( b ) Opt out ( 1 ) In general A financial institution may not disclose nonpublic personal information to a nonaffiliated third party unless ( A ) such financial institution clearly and conspicuously discloses to the consumer, in writing or in electronic form or other form permitted by the regulations prescribed under section 6804 of this title, that such information may be disclosed to such third party ; ( B ) the consumer is given the opportunity, before the time that such information is initially disclosed, to direct that such information not be disclosed to such third party ; and ( C ) the consumer is given an explanation of how the consumer can exercise that nondisclosure option.

( 2 ) Exception This subsection shall not prevent a financial institution from providing nonpublic personal information to a nonaffiliated third party to perform services for or functions on behalf of the financial institution, including marketing of the financial institutions own products or services, or financial products or services offered pursuant to joint agreements between two or more financial institutions that comply with the requirements imposed by the regulations prescribed under section 6804 of this title, if the financial institution fully discloses the providing of such information and enters into a contractual agreement with the third party that requires the third party to maintain the confidentiality of such information. 

( c ) Limits on reuse of information Except as otherwise provided in this subchapter, a nonaffiliated third party that receives from a financial institution nonpublic personal information under this section shall not, directly or through an affiliate of such receiving third party, disclose such information to any other person that is a nonaffiliated third party of both the financial institution and such receiving third party, unless such disclosure would be lawful if made directly to such other person by the financial institution. 

( d ) Limitations on the sharing of account number information for marketing purposes A financial institution shall not disclose, other than to a consumer reporting agency, an account number or similar form of access number or access code for a credit card account, deposit account, or transaction account of a consumer to any nonaffiliated third party for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer. 

( e ) General exceptions Subsections ( a ) and ( b ) shall not prohibit the disclosure of nonpublic personal information ( 1 ) as necessary to effect, administer, or enforce a transaction requested or authorized by the consumer, or in connection with ( A ) servicing or processing a financial product or service requested or authorized by the consumer ; ( B ) maintaining or servicing the consumers account with the financial institution, or with another entity as part of a private label credit card program or other extension of credit on behalf of such entity ; or ( C ) a proposed or actual securitization, secondary market sale ( including sales of servicing rights ), or similar transaction related to a transaction of the consumer ; ( 2 ) with the consent or at the direction of the consumer ; ( 3 ) ( A ) to protect the confidentiality or security of the financial institutions records pertaining to the consumer, the service or product, or the transaction therein ; ( B ) to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability ; ( C ) for required institutional risk control, or for resolving customer disputes or inquiries ; ( D ) to persons holding a legal or beneficial interest relating to the consumer ; or ( E ) to persons acting in a fiduciary or representative capacity on behalf of the consumer ; ( 4 ) to provide information to insurance rate advisory organizations, guaranty funds or agencies, applicable rating agencies of the financial institution, persons assessing the institutions compliance with industry standards, and the institutions attorneys, accountants, and auditors ; ( 5 ) to the extent specifically permitted or required under other provisions of law and in accordance with the Right to Financial Privacy Act of 1978 [ 12 U.S.C. 3401 et seq. ], to law enforcement agencies ( including the Bureau of Consumer Financial Protection [ 1 ] a Federal functional regulator, the Secretary of the Treasury with respect to subchapter II of chapter 53 of title 31, and chapter 2 of title I of Public Law 91508 ( 12 U.S.C. 19511959 ), a State insurance authority, or the Federal Trade Commission ), self-regulatory organizations, or for an investigation on a matter related to public safety ; ( 6 ) ( A ) to a consumer reporting agency in accordance with the Fair Credit Reporting Act [ 15 U.S.C. 1681 et seq. ], or ( B ) from a consumer report reported by a consumer reporting agency ; ( 7 ) in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit if the disclosure of nonpublic personal information concerns solely consumers of such business or unit; or ( 8 ) to comply with Federal, State, or local laws, rules, and other applicable legal requirements ; to comply with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by Federal, State, or local authorities ; or to respond to judicial process or government regulatory authorities having jurisdiction over the financial institution for examination, compliance, or other purposes as authorized by law. 

15 U.S. Code 1681- Congressional findings and statement of purpose ( a ) Accuracy and fairness of credit reporting The Congress makes the following findings : ( 1 ) The banking system is dependent upon fair and accurate credit reporting. Inaccurate credit reports directly impair the efficiency of the banking system, and unfair credit reporting methods undermine the public confidence which is essential to the continued functioning of the banking system. 
( 2 ) An elaborate mechanism has been developed for investigating and evaluating the credit worthiness, credit standing, credit capacity, character, and general reputation of consumers.

( 3 ) Consumer reporting agencies have assumed a vital role in assembling and evaluating consumer credit and other information on consumers.

( 4 ) There is a need to insure that consumer reporting agencies exercise their grave responsibilities with fairness, impartiality, and a respect for the consumers right to privacy. 
( b ) Reasonable procedures It is the purpose of this subchapter to require that consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information in accordance with the requirements of this subchapter. 

CFR 313.4 Initial privacy notice to consumers required. 
( a ) Initial notice requirement. You must provide a clear and conspicuous notice that accurately reflects your privacy policies and practices to : ( 1 ) Customer. An individual who becomes your customer, not later than when you establish a customer relationship, except as provided in paragraph ( e ) of this section; and ( 2 ) Consumer. A consumer, before you disclose any nonpublic personal information about the consumer to any nonaffiliated third party, if you make such a disclosure other than as authorized by 313.14 and 313.15. 

( b ) When initial notice to a consumer is not required. You are not required to provide an initial notice to a consumer under paragraph ( a ) of this section if : ( 1 ) You do not disclose any nonpublic personal information about the consumer to any nonaffiliated third party, other than as authorized by 313.14 and 313.15 ; and ( 2 ) You do not have a customer relationship with the consumer.

( c ) When you establish a customer relationship ( 1 ) General rule. You establish a customer relationship when you and the consumer enter into a continuing relationship. 

( 2 ) Special rule for loans. You establish a customer relationship with a consumer when you originate a loan to the consumer for personal, family, or household purposes. If you subsequently transfer the servicing rights to that loan to another financial institution, the customer relationship transfers with the servicing rights. 

( XXXX ) Examples ( i ) Examples of establishing a customer relationship. You establish a customer relationship when the consumer : ( A ) Executes the contract to obtain credit from you or purchase insurance from you; or ( B ) Executes the lease for personal property with you. 

( ii ) Examples of loan rule. You establish a customer relationship with a consumer who obtains a loan for personal, family, or household purposes when you : ( A ) Originate the loan to the consumer and retain the servicing rights; or ( B ) Purchase the servicing rights to the consumer 's loan. 

( d ) Existing customers. When an existing customer obtains a new financial product or service from you that is to be used primarily for personal, family, or household purposes, you satisfy the initial notice requirements of paragraph ( a ) of this section as follows : ( 1 ) You may provide a revised privacy notice, under 313.8, that covers the customer 's new financial product or service; or ( 2 ) If the initial, revised, or annual notice that you most recently provided to that customer was accurate with respect to the new financial product or service, you do not need to provide a new privacy notice under paragraph ( a ) of this section.

( e ) Exceptions to allow subsequent delivery of notice ( 1 ) General. You may provide the initial notice required by paragraph ( a ) ( 1 ) of this section within a reasonable time after you establish a customer relationship if : ( i ) Establishing the customer relationship is not at the customer 's election; or ( ii ) Providing notice not later than when you establish a customer relationship would substantially delay the customer 's transaction and customer agrees to receive the notice at a later time.

( 2 ) Examples of exceptions ( i ) Substantial delay of customer 's transaction. Providing notice not later than when you establish a customer relationship would substantially delay the customer 's transaction when you and the individual agree over the telephone to enter into a customer relationship involving prompt delivery of the financial product or service.

( ii ) No substantial delay of customer 's transaction. Providing notice not later than when you establish a customer relationship would not substantially delay the customer 's transaction when the relationship is initiated in person at your office or through other means by which the customer may view the notice, such as through a website.

( f ) Delivery. When you are required to deliver an initial privacy notice by this section, you must deliver it according to 313.9. If you use a short-form initial notice for non-customers according to 313.6 ( d ), you may deliver your privacy notice according to 313.6 ( d ) ( 3 ). 

[ 65 FR 33677, XX/XX/XXXX, as amended at 86 FR 70026, XXXX XXXX, XXXX ] 313.5 Annual privacy notice to customers required. 

( a ) In general ( 1 ) General rule. Except as provided by paragraph ( e ) of this section, you must provide a clear and conspicuous notice to customers that accurately reflects your privacy policies and practices not less than annually during the continuation of the customer relationship. Annually means at least once in any period of 12 consecutive months during which that relationship exists. You may define the 12-consecutive-month period, but you must apply it to the customer on a consistent basis.

( 2 ) Example. You provide a notice annually if you define the 12-consecutive-month period as a calendar year and provide the annual notice to the customer once in each calendar year following the calendar year in which you provided the initial notice. For example, if a customer opens an account on any day of year 1, you must provide an annual notice to that customer by XX/XX/XXXX of year XXXX. 

( b ) ( 1 ) Termination of customer relationship. You are not required to provide an annual notice to a former customer. 

( 2 ) Examples. Your customer becomes a former customer when : ( i ) In the case of a closed-end loan, the customer pays the loan in full, you charge off the loan, or you sell the loan without retaining servicing rights. 

( ii ) In the case of mortgage or vehicle loan brokering services, your customer has obtained a loan through you ( and you no longer provide any statements or notices to the customer concerning that relationship ), or has ceased using your services for such purposes. 

( iii ) In cases where there is no definitive time at which the customer relationship has terminated, you have not communicated with the customer about the relationship for a period of 12 consecutive months, other than to provide annual privacy notices or promotional material.

( c ) Special rule for loans. If you do not have a customer relationship with a consumer under the special rule for loans in 313.4 ( c ) ( 2 ), then you need not provide an annual notice to that consumer under this section. 

( d ) Delivery. When you are required to deliver an annual privacy notice by this section, you must deliver it according to 313.9.

( e ) Exception to annual privacy notice requirement ( 1 ) When exception available. You are not required to deliver an annual privacy notice if you : ( i ) Provide nonpublic personal information to nonaffiliated third parties only in accordance with the provisions of 313.13, 313.14, or 313.15 ; and ( ii ) Have not changed your policies and practices with regard to disclosing nonpublic personal information from the policies and practices that were disclosed to the customer under 313.6 ( a ) ( 2 ) through ( 5 ) and ( 9 ) in the most recent privacy notice provided pursuant to this part.

( 2 ) Delivery of annual privacy notice after financial institution no longer meets requirements for exception. If you have been excepted from delivering an annual privacy notice pursuant to paragraph ( e ) ( 1 ) of this section and change your policies or practices in such a way that you no longer meet the requirements for that exception, you must comply with paragraph ( e ) ( 2 ) ( i ) or ( ii ) of this section, as applicable. 

( i ) Changes preceded by a revised privacy notice. If you no longer meet the requirements of paragraph ( e ) ( 1 ) of this section because you change your policies or practices in such a way that 313.8 requires you to provide a revised privacy notice, you must provide an annual privacy notice in accordance with the timing requirement in paragraph ( a ) of this section, treating the revised privacy notice as an initial privacy notice.

( ii ) Changes not preceded by a revised privacy notice. If you no longer meet the requirements of paragraph ( e ) ( 1 ) of this section because you change your policies or practices in such a way that 313.8 does not require you to provide a revised privacy notice, you must provide an annual privacy notice within 100 days of the change in your policies or practices that causes you to no longer meet the requirement of paragraph ( e ) ( 1 ). 

( iii ) Examples. 

( A ) You change your policies and practices in such a way that you no longer meet the requirements of paragraph ( e ) ( 1 ) of this section effective XX/XX/XXXX of year XXXX. Assuming you define the 12-consecutive-month period pursuant to paragraph ( a ) of this section as a calendar year, if you were required to provide a revised privacy notice under 313.8 and you provided that notice on XX/XX/XXXX of year XXXX, you must provide an annual privacy notice by XX/XX/XXXX of year XXXX. If you were not required to provide a revised privacy notice under 313.8, you must provide an annual privacy notice by XX/XX/XXXX of year XXXX. 

( B ) You change your policies and practices in such a way that you no longer meet the requirements of paragraph ( e ) ( 1 ) of this section, and so provide an annual notice to your customers. After providing the annual notice to your customers, you once again meet the requirements of paragraph ( e ) ( 1 ) of this section for an exception to the annual notice requirement. You do not need to provide additional annual notice to your customers until such time as you no longer meet the requirements of paragraph ( e ) ( 1 ) of this section. 

[ 65 FR 33677, XX/XX/XXXX, as amended at 86 FR 70026, XXXX XXXX, XXXX ] 313.6 Information to be included in privacy notices. 

( a ) General rule. The initial, annual, and revised privacy notices that you provide under 313.4, 313.5, and 313.8 must include each of the following items of information that applies to you or to the consumers to whom you send your privacy notice, in addition to any other information you wish to provide : ( 1 ) The categories of nonpublic personal information that you collect ; ( 2 ) The categories of nonpublic personal information that you disclose ; ( 3 ) The categories of affiliates and nonaffiliated third parties to whom you disclose nonpublic personal information, other than those parties to whom you disclose information under 313.14 and 313.15 ; ( 4 ) The categories of nonpublic personal information about your former customers that you disclose and the categories of affiliates and nonaffiliated third parties to whom you disclose nonpublic personal information about your former customers, other than those parties to whom you disclose information under 313.14 and 313.15 ; ( 5 ) If you disclose nonpublic personal information to a nonaffiliated third party under 313.13 ( and no exception under 313.14 or 313.15 applies to that disclosure ), a separate statement of the categories of information you disclose and the categories of third parties with whom you have contracted ; ( 6 ) An explanation of the consumer 's right under 313.10 ( a ) to opt out of the disclosure of nonpublic personal information to nonaffiliated third parties, including the method ( s ) by which the consumer may exercise that right at that time ; ( 7 ) Any disclosures that you make under section 603 ( d ) ( 2 ) ( A ) ( iii ) of the Fair Credit Reporting Act ( 15 U.S.C. 1681a ( d ) ( 2 ) ( A ) ( iii ) ) ( that is, notices regarding the ability to opt out of disclosures of information among affiliates ) ; ( 8 ) Your policies and practices with respect to protecting the confidentiality and security of nonpublic personal information; and ( 9 ) Any disclosure that you make under paragraph ( b ) of this section.

( b ) Description of nonaffiliated third parties subject to exceptions. If you disclose nonpublic personal information to third parties as authorized under 313.14 and 313.15, you are not required to list those exceptions in the initial or annual privacy notices required by 313.4 and 313.5. When describing the categories with respect to those parties, it is sufficient to state that you make disclosures to other nonaffiliated companies for your everyday business purposes, such as to process transactions, maintain account ( s ), respond to court orders and legal investigations, or report to credit bureaus.

( c ) Examples ( 1 ) Categories of nonpublic personal information that you collect. You satisfy the requirement to categorize the nonpublic personal information that you collect if you list the following categories, as applicable : ( i ) Information from the consumer ; ( ii ) Information about the consumer 's transactions with you or your affiliates ; ( iii ) Information about the consumer 's transactions with nonaffiliated third parties ; and ( iv ) Information from a consumer reporting agency. 

( 2 ) Categories of nonpublic personal information you disclose ( i ) You satisfy the requirement to categorize the nonpublic personal information that you disclose if you list the categories described in paragraph ( e ) ( 1 ) of this section, as applicable, and a few examples to illustrate the types of information in each category.

( ii ) If you reserve the right to disclose all of the nonpublic personal information about consumers that you collect, you may simply state that fact without describing the categories or examples of the nonpublic personal information you disclose.

( 3 ) Categories of affiliates and nonaffiliated third parties to whom you disclose. You satisfy the requirement to categorize the affiliates and nonaffiliated third parties to whom you disclose nonpublic personal information if you list them using the following categories, as applicable, and a few applicable examples to illustrate the significant types of third parties covered in each category. 

( i ) Financial service providers, followed by illustrative examples such as mortgage bankers, securities broker-dealers, and insurance agents. 

( ii ) Non-financial companies, followed by illustrative examples such as retailers, magazine publishers, airlines, and direct marketers ; and ( iii ) Others, followed by examples such as nonprofit organizations. 

( 4 ) Disclosures under exception for service providers and joint marketers. If you disclose nonpublic personal information under the exception in 313.13 to a nonaffiliated third party to market products or services that you offer alone or jointly with another financial institution, you satisfy the disclosure requirement of paragraph ( a ) ( 5 ) of this section if you : ( i ) List the categories of nonpublic personal information you disclose, using the same categories and examples you used to meet the requirements of paragraph ( a ) ( 2 ) of this section, as applicable ; and ( ii ) State whether the third party is : ( A ) A service provider that performs marketing services on your behalf or on behalf of you and another financial institution ; or ( B ) A financial institution with whom you have a joint marketing agreement. 

( 5 ) Simplified notices. If you do not disclose, and do not wish to reserve the right to disclose, nonpublic personal information about customers or former customers to affiliates or nonaffiliated third parties except as authorized under 313.14 and 313.15, you may simply state that fact, in addition to the information you must provide under paragraphs ( a ) ( 1 ), ( a ) ( 8 ), ( a ) ( 9 ), and ( b ) of this section.

( 6 ) Confidentiality and security. You describe your policies and practices with respect to protecting the confidentiality and security of nonpublic personal information if you do both of the following : ( i ) Describe in general terms who is authorized to have access to the information; and ( ii ) State whether you have security practices and procedures in place to ensure the confidentiality of the information in accordance with your policy. You are not required to describe technical information about the safeguards you use. 

( d ) Short-form initial notice with opt out notice for non-customers ( 1 ) You may satisfy the initial notice requirements in 313.4 ( a ) ( 2 ), 313.7 ( b ), and 313.7 ( c ) for a consumer who is not a customer by providing a short-form initial notice at the same time as you deliver an opt out notice as required in 313.7.

( 2 ) A short-form initial notice must : ( i ) Be clear and conspicuous ; ( ii ) State that your privacy notice is available upon request ; and ( iii ) Explain a reasonable means by which the consumer may obtain that notice. 

( 3 ) You must deliver your short-form initial notice according to 313.9. You are not required to deliver your privacy notice with your short-form initial notice. You instead may simply provide the consumer a reasonable means to obtain your privacy notice. If a consumer who receives your short-form notice requests your privacy notice, you must deliver your privacy notice according to 313.9.

( 4 ) Examples of obtaining privacy notice. You provide a reasonable means by which a consumer may obtain a copy of your privacy notice if you : ( i ) Provide a toll-free telephone number that the consumer may call to request the notice; or ( ii ) For a consumer who conducts business in person at your office, maintain copies of the notice on hand that you provide to the consumer immediately upon request.

( e ) Future disclosures. Your notice may include : ( 1 ) Categories of nonpublic personal information that you reserve the right to disclose in the future, but do not currently disclose ; and ( 2 ) Categories of affiliates or nonaffiliated third parties to whom you reserve the right in the future to disclose, but to whom you do not currently disclose, nonpublic personal information.

( f ) Model privacy form. Pursuant to 313.2 ( a ) of this part, a model privacy form that meets the notice content requirements of this section is included in appendix A of this part. 

[ 65 FR 33677, XX/XX/XXXX, as amended at 74 FR 62965, XXXX XXXX, XXXX ] 313.7 Form of opt out notice to consumers ; opt out methods. 

( a ) ( 1 ) Form of opt out notice. If you are required to provide an opt out notice under 313.10 ( a ), you must provide a clear and conspicuous notice to each of your consumers that accurately explains the right to opt out under that section. The notice must state : ( i ) That you disclose or reserve the right to disclose nonpublic personal information about your consumer to a nonaffiliated third party ; ( ii ) That the consumer has the right to opt out of that disclosure; and ( iii ) A reasonable means by which the consumer may exercise the opt out right.

( 2 ) Examples ( i ) Adequate opt out notice. You provide adequate notice that the consumer can opt out of the disclosure of nonpublic personal information to a nonaffiliated third party if you : ( A ) Identify all of the categories of nonpublic personal information that you disclose or reserve the right to disclose, and all of the categories of nonaffiliated third parties to which you disclose the information, as described in 313.6 ( a ) ( 2 ) and ( 3 ) and state that the consumer can opt out of the disclosure of that information; and ( B ) Identify the financial products or services that the consumer obtains from you, either singly or jointly, to which the opt out direction would apply. 

( ii ) Reasonable opt out means. You provide a reasonable means to exercise an opt out right if you : ( A ) Designate check-off boxes in a prominent position on the relevant forms with the opt out notice ; ( B ) Include a reply form that includes the address to which the form should be mailed ; or ( C ) Provide an electronic means to opt out, such as a form that can be sent via electronic mail or a process at your web site, if the consumer agrees to the electronic delivery of information ; or ( D ) Provide a toll-free telephone number that consumers may call to opt out. 

( iii ) Unreasonable opt out means. You do not provide a reasonable means of opting out if : ( A ) The only means of opting out is for the consumer to write his or her own letter to exercise that opt out right; or ( B ) The only means of opting out as described in any notice subsequent to the initial notice is to use a check-off box that you provided with the initial notice but did not include with the subsequent notice. 

( iv ) Specific opt out means. You may require each consumer to opt out through a specific means, as long as that means is reasonable for that consumer.

( b ) Same form as initial notice permitted. You may provide the opt out notice together with or on the same written or electronic form as the initial notice you provide in accordance with 313.4.

( c ) Initial notice required when opt out notice delivered subsequent to initial notice. If you provide the opt out notice later than required for the initial notice in accordance with 313.4, you must also include a copy of the initial notice with the opt out notice in writing or, if the consumer agrees, electronically.

( d ) Joint relationships.

( 1 ) If two or more consumers jointly obtain a financial product or service from you, you may provide a single opt out notice, unless one or more of those consumers requests a separate opt out notice. Your opt out notice must explain how you will treat an opt out direction by a joint consumer ( as explained in paragraph ( d ) ( 5 ) ( ii ) of this section ).

( 2 ) Any of the joint consumers may exercise the right to opt out. You may either : ( i ) Treat an opt out direction by a joint consumer as applying to all of the associated joint consumers; or ( ii ) Permit each joint consumer to opt out separately.

( 3 ) If you permit each joint consumer to opt out separately, you must permit one of the joint consumers to opt out on behalf of all of the joint consumers.

( 4 ) You may not require all joint consumers to opt out before you implement any opt out direction. 

( 5 ) Example. If XXXX and XXXX have a joint credit card account with you and arrange for you to send statements to XXXX 's address, you may do any of the following, but you must explain in your opt out notice which opt out policy you will follow : ( i ) Send a single opt out notice to XXXX 's address, but you must accept an opt out direction from either XXXX or XXXX. 

( ii ) Treat an opt out direction by either XXXX or XXXX as applying to the entire account. If you do so, and XXXX opts out, you may not require XXXX to opt out as well before implementing XXXX 's opt out direction. 

( iii ) PermiXXXX XXXX and XXXX to make different opt out directions. If you do so, ( A ) You must permit XXXX and XXXX to opt out for each other; ( B ) If both opt out, you must permit both to notify you in a single response ( such as on a form or through a telephone call ) ; and ( C ) If XXXX opts out and XXXX does not, you may only disclose nonpublic personal information about XXXX, but not about XXXX and not about XXXX and XXXX jointly. 

( e ) Time to comply with opt out. You must comply with a consumer 's opt out direction as soon as reasonably practicable after you receive it.

( f ) Continuing right to opt out. A consumer may exercise the right to opt out at any time.

( g ) Duration of consumer 's opt out direction.

( 1 ) A consumer 's direction to opt out under this section is effective until the consumer revokes it in writing or, if the consumer agrees, electronically. 

( 2 ) When a customer relationship terminates, the customer 's opt out direction continues to apply to the nonpublic personal information that you collected during or related to that relationship. If the individual subsequently establishes a new customer relationship with you, the opt out direction that applied to the former relationship does not apply to the new relationship.

( h ) Delivery. When you are required to deliver an opt out notice by this secti

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with non-monetary relief