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Can I collect bank account information from participants in Vermont? What are the requirements?

Yes, you can collect bank account information from participants in Vermont, but you must obtain their consent and comply with the requirements of the Vermont Consumer Protection Rule.

Requirements for Collecting Bank Account Information in Vermont

The Vermont Consumer Protection Rule VTCR 21-010-016 § 13 prohibits financial institutions from disclosing, other than to a consumer reporting agency, an account number or similar form of access number or access code for a consumer’s transaction account to any nonaffiliated third party for use in telemarketing, direct mail marketing or other marketing through electronic mail to the consumer. However, there are exceptions to this rule, such as disclosing the account number to the financial institution’s agent or service provider solely in order to perform marketing for the financial institution’s own products or services, as long as the service provider is not authorized to directly initiate charges to the account, or to a participant in a private label credit card or affinity or similar program where the participants in the program are identified to the customer when the customer enters into the program [1.1][2.1].

Regarding the collection of nonpublic personal financial information, the Vermont Consumer Protection Rule VTCR 21-030-004 § 16 provides exceptions to notice and opt-in requirements for disclosure of nonpublic personal financial information. The requirements for initial notice and opt-in requirements do not apply when disclosing nonpublic personal financial information with the consent or at the direction of the consumer, provided that the consumer has not revoked the consent or direction. Additionally, financial institutions may disclose nonpublic personal financial information to service providers and joint marketing under certain conditions [1.2][2.2][1.3].

Therefore, to collect bank account information from participants in Vermont, you must obtain their consent and comply with the requirements of the Vermont Consumer Protection Rule.

Source(s):
Jurisdiction

Vermont