WASHINGTON (4/11/16)--Credit unions confused by the in-progress changes to annual privacy notice requirements have a new resource, courtesy of the Credit Union National Association (CUNA). CUNA has developed a privacy notice opt-out checklist, a comprehensive resource intended to assist credit unions until the rule is finalized.
Changes to privacy notice requirements were signed into law in December 2015, following a number of years spent by CUNA asking for changes from regulators and members of Congress. CUNA was a strong supporter of the bill that was eventually included as part of the Fixing America’s Surface Transportation Act.
The list, developed by CUNA’s Senior Federal Compliance Counsel Colleen Kelly, asks credit unions about sharing of nonpublic personal information with third parties and if those third parties are “affiliates” of the credit union. The list lays out the requirements for financial institutions that disclose nonpublic personal information with nonaffiliated third parties.
Those institutions are required to:
These requirements do not have to be met unless one of 17 exceptions apply, as listed on CUNA’s checklist.
CUNA’s Compliance Community contains CUNA’s CompBlog, as well as a discussion board and numerous other resources and networking opportunities for credit union compliance professionals around the world.