This particular Best Practice seems to be creating the most buzz. What exactly is NPI? What is the best way to protect it? What is it going to take to be compliant? What are your thoughts.

Non-public Personal Information (NPI)

Personally identifiable data, for example: information provided by a customer on a form or application, information about a customer’s transactions, or any other information about a customer which is otherwise unavailable to the general public. NPI includes first name or first initial and last name coupled with any of the following: Social Security Number, driver’s license number, state-issued ID number, credit card number, debit card number, or other financial account numbers.

Best Practice

Adopt and maintain a written privacy and information security program to protect NPI as required by law.

Reason

Federal and state laws require title companies to develop a written information security program that explains how NPI is protected.

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