Why does the Privacy Rule sometimes refer to consumers and other times to customers? Aren customers also consumers?
A. All customers are consumers, but not all consumers are customers. A consumer is an individual who obtains a financial product or service from you that is primarily for personal, family, or household purposes. A financial product or service includes the evaluation or brokerage of information collected in connection with a request or application, such as a bank’s review of loan application materials to determine whether an applicant qualifies for a loan. A customer is a type of consumer, namely, an individual who has an ongoing relationship with you under which you provide a financial product or service. Note that neither a business nor an individual who obtains a financial product or service for business purposes is a consumer or a customer under the Privacy Rule. The rule distinguishes consumers from customers because your responsibilities to provide notices to consumers and to customers differ in several respects.
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