SUMMONSES: Right to Financial Privacy Act

ID:
UILC:
CCA-06031123-15
75.12.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201536018
Release Date: 9/4/2015
From: ---
Sent: Wednesday, June 3, 2015 11:23 AM
To: ---
Subject: FW: Assistance with privacy question
I don’t have any actual experience in dealing with the Federal Reserve, but my reading of item 6 and the exception found in section 3413 finds that it would serve as “a statement as to why the Act does not apply to the request.” I believe, however, that the exception is most often used in conjunction with summonsed information for which particular procedures are set forth in Title 26 . As to protecting the information, I don’t see that requirement enumerated below, but the protections that the IRS accords return information would more than satisfy any protections accorded by the RFPA.
Question for you, are you okay with the requirement in item 5 which states: “A commitment that the information requested shall not be disclosed to any person outside the agency without the written permission of the Board or its General Counsel.” ---------------