PATRIOT ACT NOTICE & PRIVACY POLICY AND PRACTICES
Trellis Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Policy/US Patriot Act Notice
This policy conforms to Section 326 of the USA Patriot Act. The Act helps the government fight the funding of terrorism and money laundering activities. Federal law requires all financial institutions to obtain, verify and record information which identifies each person seeking specific services from Trellis.
Persons subject to verification of identity:
Any person(s) seeking counseling, lending or real estate services
Any person(s) seeking to be a joint applicant for Trellis services
Any person(s) seeking to be a co-signer or co-applicant for any Trellis service
Any person(s) seeking information on a current loan, application, counseling file or purchase contract.
Under section 103.11 (z) a person includes individuals, corporations, partnerships, trusts, estates, joint stock companies, associations, syndicates, joint ventures, other unincorporated organizations or groups, certain Indian Tribes and all entities recognized as legal personalities.
Two forms of identification (ID) are required. A primary ID must be a driver’s license, US passport or state photo ID with apicture. A primary ID is required when opening a counseling file, foreclosure case, loan application or purchase contract even for existing clients. A photo credit card or debit card, foreign passport or employee badge or other non-government issued photo ID maybe used as a secondary ID.
Required Customer Information: At a minimum, the following information must be obtained for all counseling clients and loan applicants:
Name
Date of Birth
Physical address, no PO boxes
Social Security Number(s) or taxpayer identification number-
Primary form of identification
Secondary form of identification
Signature(s)-matches identification
Verification of Clients seeking information or status on a current loan, counseling file or sales contract with Trellis:
If in-person and unknown: Verify identify via valid primary identification which matches the information in the loan, counseling file or sales contract
If inquiring by phone:
verify identity by requesting the following as needed, which matches the information in the loan, counseling file or sales contract: name, social security number and date of birth, loan number, amount of payment.
PRIVACY POLICY AND PRACTICES
– PART I
Trellis and Trellis Community Development is committed to assuring the privacy of individuals and/or families who have contacted us for assistance. We realize that the concerns you bring to us are highly personal in nature. We assure you that all information shared both orally and in writing will be managed within legal and ethical considerations. Your “nonpublic personal information,” such as your total debt information, income, living expenses and personal information concerning your financial circumstances, will be provided to creditors, program monitors, and others only with your authorization and signature on the Foreclosure Mitigation Counseling Agreement. We may also use anonymous aggregated case file information for the purpose of evaluating our services, gathering valuable research information, and designing future programs.
TYPES OF INFORMATION THAT WE GATHER ABOUT YOU
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- Information we receive from you orally, on applications or other forms, such as your name, address, social security number, assets, and income;
- Information about your transactions with us, your creditors, or others, such as your account balance, payment history, parties to transactions and credit card usage; and
- Information we receive from a credit-reporting agency, such as your credit history.
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YOU MAY OPT-OUT OF CERTAIN DISCLOSURES
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- You have the opportunity to “opt-out” of disclosures of your nonpublic personal information to third parties (such as your creditors), that is, direct us not to make those disclosures.
- If you choose to “opt-out”, we will not be able to answer questions from your creditors. If at any time, you wish to change your decision with regard to your “opt-out”, you may call us at 602-258-1659 and do so.
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RELEASE OF YOUR INFORMATION TO THIRD PARTIES
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- So long as you have not opted-out, we may disclose some or all of the information that we collect, as described above, to your creditors or third parties where we have determined that it would be helpful to you, would aid us in counseling you, or is a requirement of grant awards which make our services possible.
- We may also disclose any nonpublic personal information about you or former customers to anyone as permitted by law (e.g., if we are compelled by legal process).
- Within the organization, we restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
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PRIVACY POLICY AND PRACTICES – PART II
DIRECTING US NOT TO MAKE DISCLOSURES TO THIRD PARTIES
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- The Federal government requests information to monitor compliance with Federal statutes or local laws that prohibit discrimination in housing.
- To offer free client services to the public, our funding and assistance to you is based on demographics and statistical data, i.e., household income, family size, gender, county, ethnicity, race, age, etc. Name, address, phone number, social security number, and birth date, are not shared without your expressed written approval.
- If you prefer that we not disclose compliance information, Trellis and Trellis Community Development will not be funded for its’ service to you and Trellis and Trellis Community Development may opt to discontinue counseling. (Disclosures required or allowed by federal or local laws will still be permitted.)
- If you elect not to disclose compliance information, and you have properly informed Trellis and Trellis Community Development as to your decision, please allow 30 days from the receipt of your notification for your authorization restrictions to be noted in your file.
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PRIVACY POLICY AND PRACTICES – PART III
ONLINE DATA COLLECTION
This Privacy Policy discloses the privacy practices for Trellis and Trellis Community Development and our website; https://www.trellisaz.org.com. This privacy policy applies only to information collected by this website, unless stated otherwise.
What information we collect, how it’s used and shared.
While on this website you may choose to provide us with your contact information to include: name, phone number, email address. We do not and will not share your information with any third parties that are not part of or organization. Our organization includes Trellis and Trellis Community Development, a nonprofit dedicated to making stable homes and communities possible in Arizona, and Arboles Home Mortgage LLC, a social enterprise company that gives 100% of its profits to Trellis and Trellis Community Development.
We will use the information you provide to contact you, regarding the reason you responded to us.
We may contact you in the future via email to tell you about new home opportunities, lending options, or informational newsletters.
All emails will have an opt-out option on the bottom of the email. You may choose to opt-out using the link or by emailing us at info@trellisaz.org
Your control and access over your information
You may opt out at any time by clicking on the opt-out link in email communication with you or by contacting us via the email, info@trellisaz.org, or calling us at the number provided on our website.
You may also contact us to:
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- Check what information we have about you, if any.
- Change or correct any information we have on file we have about you.
- Delete any data we have on file about you.
- Express concerns about the use of your data.
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Protecting your information
We value your information and take steps to protect it. Our website uses Secure Socket Layering, SSL, protocols to protect the data being transmitted from your browser to our server. Your data inside our organization is only shared with employees who need the information to perform their specific job. The computers/servers where your data is kept is stored in a secure environment. While we do take all steps to protect this data, we cannot guarantee, ensure or warrant that any information you transmit to use is 100% secure.
Use of cookies
We use assign “cookies” on this site. Cookies are data stored on a website visitors hard drive to help improve access to our website and identify new or repeat visitors to our site. Cookies can help us track and target the interests of our users to improve the experience on our site. We do not use cookies to personally identify you or other visitors to this site.
Cookies are also used for statistical analysis purposes as we use Google Analytics and Facebook Analytics to show how users interact with our website.
You may choose to adjust your browser settings to not automatically accept cookies should you prefer.
We also use cookies to assist with remarketing by Google Adwords and Facebook Ads to show you our ads on other websites, or social media channels. The ads are shown on other sites based on visits to this website. You can op out of these ads by visiting third-party vendors Google Ads or Facebook ads settings in the ad and on their websites: http://www.google.com/settings/ads, https://www.facebook.com/ads/settings.
Links
This website contains links to other sites. Please be aware of when you leave our site and read the privacy policies of other sites that may collect your personal information. We are not responsible when you click on a link and leave this site as other sites have their own privacy policies and content not controlled by us.
Your consent
By using our website, you are consenting to this privacy policy.
Policy modifications
Trellis and Trellis Community Development reserves the right to change this Privacy Policy at any time; we will place a notice of changes on this page. If you have questions about our policies, please contact: info@trellisaz.org