TOPIC: Vendors

Sharing a Credit Report with a Title Company / 3rd Parties

Director at a bank ($16.3BUSA)
Good Afternoon CBANC Family,

I feel like I am going back to basics with this question. 

Are we allowed to share a credit report with a third party? Specifically, if a title company is unable to verify the number/amount of liens attached to a borrower or to simply verify their identity to remove certain judgments, they sometimes reach out to us to provide them with our borrower's credit report to confirm if some of these liens or judgments are reporting as a tradeline.

Are we allowed to do so? If we are allowed to do so, would a Borrower's Certification & Authorization be sufficient to be able to do so? Or are there any other rules or disclosures I am drawing a blank on?

Thank you for any input/clarification you can provide.

Categorizing GLBA Vendors

Manager at a bank ($1.2BUSA)
Hello,
I am curious about how others are identifying and classifying their GLBA vendors. Currently,  I am classifying vendors as GLBA if they transmit, store or access NPPI. What are your thoughts about GLBA classification if a vendor only transmits but doesn't store NPPI? Thanks in advance for your thoughts.