NPI Rules and Consequences
Bank of America agents are responsible for ensuring that necessary precautions are taken to protect both customer and broker/agent information from the risk of exposure. This includes safeguarding their access to Equator and your user identification sign-in credentials.
The agent's sign-in information may not be shared with anyone for any reason. Doing so is a violation of Bank of America policy and can result in termination. If agents have knowledge (or suspect) that their access credentials have been compromised, they must contact Equator support at support@equator.com or via telephone at 310.469.9017.
As a reminder, when using Equator for REO Relocation Assistance or other REO transactions, you should never upload nonpublic Information (NPI) to the system. Audits are conducted on a regular basis to ensure your compliance with this policy.
Example: When setting up fee payments directly to a homeowners association, the task could call for a W-9 with a Tax Identification Number for the homeowners association. Completing this task would not violate NPI regulations as long as a Tax Identification Number is used rather than a personal Social Security number.
The following actions will occur if an agent violates this policy:
- 1st NPI offense: Agent will be notified of the offense by Bank of America and counseled on NPI policy.
- 2nd NPI offense: Agent will be placed on a watch list and new REO referrals will be suspended for 30 days.
- 3rd NPI offense: Agent will be immediately terminated.
The following items should never be uploaded to Equator:
- Social Security number
- User ID/name/password
- Income
- Personal Identification Number (PIN)
- Driver's license numbers
- Bank checking/deposit account numbers
- Bank routing number (excluding the fractional routing number at the top of the check)
- Credit/debit card numbers
- Copies of checks
- Proof of Funds letter with account numbers and account balances
- Bank statements
- FICO score
- Date of birth
- Medical records
- Credit reports
- Loan Numbers
Items that can be uploaded to Equator:
- Wiring information
- Tax Identification Number (TIN)
