Assume the same facts as Question 4 above. What if the two joint account holders with A, X and Y, have different addresses?
A. You still may provide one notice to A (unless one or more requests separate notices). However, in any communications with X and Y, you must not disclose to X the fact that A has a joint account with Y, nor may you disclose to Y that A has a joint account with X, unless you have a reasonable basis to believe this information is publicly available. Section E. Complying with the opt out provisions for joint account holders E.1. Q. I have two depositors who hold one account jointly. Must I deliver a separate opt out notice to each account holder and allow each of them to opt out individually? Suppose I mail only one opt out notice for that account, and one of the joint holders checks “I opt out” and returns it to me. To whom does the opt out decision apply? A. You may deliver either a single opt out notice to one of the account holders or a separate notice to each account holder. In either case, the notice must permit one joint account holder to opt out on behalf of all holders of the a
