Q. Must a credit union provide a risk-based pricing notice to a co-signer or guarantor?
A. No. A credit union must provide the notice only when it “grants, extends, or otherwise provides credit” to a consumer. This generally applies to anyone who applies, and is approved, for credit. The credit union doesn’t grant, extend, or otherwise provide credit to the co-signer/guarantor, who supports and assumes liability for the credit granted or extended, but doesn’t receive the credit.
Q. Can a credit union amend its account agreement to require members who still receive paper statements to convert to e-statement delivery?
A. No. Engaging in electronic transactions must be voluntary under the federal ESIGN Act. The member must affirmatively consent (opt-in) to receiving electronic statements after receiving the proper ESIGN disclosures. Although credit unions can’t require members to convert to e-statements, it can provide incentives to encourage a speedier transition.
Visit CUNA’s compliance blog— “CompBlog” —at cuna.org/compliance. Email firstname.lastname@example.org with questions or ideas for blog posts, and keep the conversation going with your peers on COBWEB, CUNA’s compliance listserv.
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