I allow joint account holders to make independent opt out elections. May I require each account holder to opt out in a separate response?
A. No. You must allow both account holders a reasonable opportunity to opt out in one response, such as one opt out form or in one call to your toll-free opt out line. E.4. Q. I allow joint account holders, X and Y, to make independent opt out elections. Suppose that X opted out, but Y did not respond. What nonpublic personal information about X and Y may I disclose? A. Because X has opted out, you must not disclose any nonpublic personal information about X, except as permitted by an exception at 313.13, 313.14, or 313.15. In addition, you must not disclose nonpublic personal information about Y except as permitted by an exception if the disclosure of that information also would disclose nonpublic personal information about X. For example, suppose that X and Y are married, share the same surname, reside at the same address, and jointly hold a savings account with you. You may disclose nonpublic personal information relating to that account about Y, such as the average monthly balance
