As the Consumer Financial Protection Bureau (CFPB) seeks comments on CUNA-advocated changes to annual privacy notice requirements, CUNA is encouraging credit union feedback as it prepares its own comment letter. Comments can be sent to CUNA before Aug. 3, and must be submitted to the CFPB by Aug. 10.
CUNA’s advocacy efforts on the legislative advocacy front led to changes in the Gramm-Leach-Bliley Act, which requires financial institutions to send annual privacy notices to consumers. The first change, made in 2014, allowed for privacy notices to be delivered through an alternate methods. For instance, instead of sending notices through the mail, credit unions could post them on a website.
The Fixing America’s Surface Transportation Act (FAST), signed into law in December 2015, eliminated the general annual privacy notice requirement, a provision strongly supported by CUNA.
The CFPB’s proposal would implement this legislation and establish deadlines for institutions resuming annual privacy notices if their practices change and cease to qualify for the exemption.
After the FAST Act was signed into law, CUNA asked for clarifications from the NCUA on its implementation. The NCUA responded with a letter stating federal credit union examiners are on notice that credit unions meeting requirements were no longer required to send annual privacy notices.