Nonpublic Personal Information
Chapters in this video
- 0:00 Consumer vs customer: the continuing relationship test
- 1:10 Business and vendor relationships are outside the scope
- 2:45 Three sources of personally identifiable financial information
- 3:26 Aggregate data safe, consumer groupings are NPI
- 4:01 When publicly available information becomes NPI
- 4:30 Opt-out timing before nonaffiliated third-party disclosures
- 5:37 Exactly three written safeguard objectives
- 6:45 Rapid-fire exam recap
What this video covers
- The difference between a consumer and a customer under Regulation S-P, and why the continuing relationship matters
- Why business, commercial, agricultural, and vendor relationships fall completely outside the consumer privacy scope
- What qualifies as nonpublic personal information (NPI), including the three sources of personally identifiable financial information
- Why aggregate or blind data without personal identifiers is not NPI, but consumer groupings derived from personally identifiable financial information are
- The oddball exception where publicly available information becomes NPI if its disclosure reveals someone is or was the firm's consumer
- The timing of opt-out rights, and why the reasonable opportunity must come before most disclosures to nonaffiliated third parties
- The exactly three objectives of written administrative, technical, and physical safeguards for customer information
Read the full lesson, free
This video's complete written lesson is free to read in the CertFuel app, no signup wall. The complete Series 99 course also includes adaptive practice questions and spaced-repetition flashcards, free through the end of 2026.