news.cuna.org/articles/108974-cfpb-privacy-notice-changes-effective-immediately

FAST Act prompts supervision, enforcement changes to privacy notices

January 6, 2016

WASHINGTON (1/6/16)--With the Credit Union National Association (CUNA)-supported modernizations to privacy notices signed into law last month, the Consumer Financial Protection Bureau (CFPB) issued a statement saying all changes are effective immediately.

Additionally, CUNA has highlighted this change to the National Credit Union Administration, which would be the entity enforcing the privacy notice requirements in many circumstance.

A provision in the Fixing America’s Surface Transportation (FAST) Act requires financial institutions to send out copies of privacy notices only when policies change.

“The CFPB recognizes that the recent statutory change on annual privacy notice requirements became effective upon the transportation bill’s enactment. The bureau has begun working with our fellow regulators to coordinate on a process to discuss further each agency's plans for rulemaking in this area given the statutory changes,” the bureau’s statement reads.

“In the meantime, the bureau is conveying to its supervision and enforcement staff that the law is effective immediately so that no financial institution is expected to comply with superseded regulatory requirements.”

The provision in the FAST Act modernizing privacy notice requirements came from a bill CUNA championed and testified in support of in recent years. As the bill was put together, CUNA outlined to Congress exactly how the regulatory relief would help credit unions better serve their members.