Effective January 2023
This policy governs all National MI employees, contractors, and service providers and applies to nonpublic personal information relating to an identifiable consumer (hereinafter referred to as “personal information”). Personal information may be received from one of National MI’s financial institution business partners, directly from the consumer/borrower, or otherwise in the normal course of providing our products or services.
It is the policy of National MI to collect only the minimum amount of personal information needed to conduct our business, and to comply with all applicable laws and regulations concerning the use and disclosure of personal information, including the Fair Credit Reporting Act, and the Gramm-Leach-Bliley Act and its implementing safeguarding regulations.
How is Personal Information Collected?
National MI’s mortgage guaranty insurance products and services originate from a business relationship with a financial institution – including but not limited to mortgage lenders, originators, aggregators, servicers, investors, government sponsored entities and housing agencies.
As such, personal information is typically transferred from the financial institution to National MI. However, in the normal course of providing our products and services, National MI may have occasion to receive additional personal information from third party sources – for example, consumer credit reporting agencies, attorneys, investigators, other service providers – or from the consumers/borrowers themselves.
What Type of Personal Information Does National MI Receive?
- Personal information concerning borrowers’ credit history and financial condition. May include credit score, existing account relationships, financial obligations, and sources and amounts of income and assets.
- Personal identifying information such as social security numbers, driver’s license numbers, addresses, phone numbers, email addresses and any other relevant contact information.
- Information concerning the location, character, and value of the property securing an insured loan, and terms of the insured loan itself.
- In the event a claim is received, National MI may obtain information relating to the circumstances of the default, as well as the borrower’s personal bankruptcy filing or other legal proceedings involving the borrower or the property which secures the loan.
- In the course of investigating potential misrepresentation we may gather information from personal interviews with the borrower, and other parties having knowledge of the borrower’s financial situation, the value and condition of the property, or the transaction itself.
What is the Personal Information Used for?
- Determining eligibility for mortgage guaranty insurance (or reinsurance), and administering and servicing such insurance;
- Evaluating and paying claims;
- Preventing or investigating fraud;
- Controlling risk;
- Recovering or mitigating losses; or
- Responding to government regulator requests for information
Other uses may be disclosed at the time of collection.
Certain personal information of California residents is subject to additional disclosures and restrictions under California laws. Personal information, for purposes of this section, means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. These laws do not apply to all personal information received, collected, or used in the course of National MI’s business operations; for example, information protected by the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act.
If you are a California resident, the following rights may apply to you, subject to applicable exceptions:
- The right to know the categories of personal information collected or disclosed in the 12 months preceding your request, as well as the sources and purposes of collection or disclosure.
- The right to delete personal information about you. We will use commercially reasonable efforts to honor your request, but may be required or permitted to keep some information for business purposes or to comply with applicable law.
- The right to non-discrimination. We will not discriminate against you because you exercise any of the consumer rights afforded to you under California law.
If you would like to exercise one of these rights, please contact us through our Solution Center at 855-317-4664 or firstname.lastname@example.org, and provide us with your name, the nature of your relationship with us, the name of your mortgage lender, if applicable, along with a way to identify your loan, and information by which we may contact you. Please note that we may require additional information from you to verify your identity and process your request, and we may not be able to honor all requests.
How Does National MI Safeguard Personal Information?
National MI employs physical, administrative and technical safeguards to protect against unauthorized collection, use or disclosure, and we take care to protect the availability, integrity and confidentiality of personal information in our possession. Personal information will be securely destroyed when no longer needed, or in accordance with applicable record retention requirements.
National MI will only disclose personal information as reasonably necessary in connection with the processing and servicing of our business – including sharing with our affiliates for purposes of mortgage guaranty reinsurance or financial guaranty reinsurance – and as otherwise required or permitted by law. We may disclose personal information as necessary in response to a subpoena, to prevent fraud, or to comply with government agency or regulator inquiries.
Social Security Number Protection
National MI is committed to safeguarding the social security numbers (SSNs) that it receives or collects in the normal course of its business. We maintain physical, technical, and administrative security procedures designed to safeguard SSNs. We protect against unauthorized third party access, and do not share SSNs except as required or permitted by law. In addition, access to SSNs is limited, and those individuals who do have access are trained on how to protect SSNs and other confidential information.
What Happens in the Event of a Security Breach Involving Personal Information?
If National MI discovers or has a reasonable belief that an event or incident has compromised personal information in our possession, we will follow established protocols for the escalation and reporting of such incidents in accordance with applicable law, and/or as agreed upon with our financial institution clients. The financial institution client, rather than National MI, is generally expected to notify their consumer customers of the event as legally required or appropriate.
Generally speaking, when you visit and navigate through our website, www.NationalMI.com, the information that you willingly provide to us, as well as certain information related to your web activities used to personalize your experience or to improve customer service, may be collected. We may use this information to respond to your inquiry, provide you with the service that you’ve requested, and/or contact you about a National MI product or service that may be of interest to you.
Law Department Attn: Chief Compliance Officer National MI 2100 Powell St, 12th Floor Emeryville, CA 94608 Or call (toll free) at 855-317-4NMI (4664)