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January 29,
2004
To: Lenders/Holders/Servicers
Participating in the Health Education
Assistance Loan (HEAL) Program
Subject: HEAL Privacy
Requirements - New Bankruptcy Court Privacy Requirements
Lender Policy Memorandum L-2004-2
The purpose of this policy memorandum is to notify HEAL lenders/holders/servicers
of the Department of Health and Human Services (DHHS), HEAL Program
new privacy requirements of all filings made in Bankruptcy Courts
as of December 1, 2003. These requirements affect all filings, including
proofs of claim and transfers of proofs of claim.
To protect the privacy
of debtors, all documents filed with the Bankruptcy Courts must
redact portions of personal identifiers. These personal identifiers
include:
Social Security Number:
Use only the last four digits of a social security number, e.g.,
XXX-XX-3448.
Names of Minor Children:
Use only the initials and last name of a minor child, e.g., J.M.
Smith.
Date of Birth: Use only
the year, e.g., XX/XX/2004.
Financial Account Numbers:
For bank or other personal financial accounts, use only the last
four digits of the account, e.g., XX-XXXXXXXX4006.
It is the responsibility
of the creditor/lender filing the documents, not the Bankruptcy
Court or DHHS, to apply these changes to court filings. Failure
to comply with these requirements may result in the Bankruptcy Court
rejecting the filing as defective.
If you have any further
questions concerning this policy memorandum, please contact Ms.
Audrey Darden-Willis at 301-443-9353.
Henry Lopez, Jr.
Director
Division of Health Careers Diversity and Development |