Privacy Policy Considerations for Your Bank Card Program

The May/June 2023 issue of the ABA Banking Journal included a Regulatory and Compliance Q&A related to co-branding relationships. The example used in the scenario closely aligns with the BBOK bank card program with your bank. The content explains the recommendation to disclose joint marketing in the bank’s privacy policy, even if you are not directly providing customer information.

We wanted to bring this content to your attention, as we know many of our bank card customers’ privacy policies do not disclose joint marketing with other financial institutions. We recommend consulting with your compliance officer to determine if any changes are needed to your privacy policy.