Regulatory Compliance
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Confusion over Annual Privacy Notice

At PolicyWorks, we have had a lot of questions about the requirement to provide an annual privacy notice, in the last few months.  Many credit unions have been confused, because last December a Bill which would reduce the requirement to provide this notice passed the House.  Unfortunately, it did not pass the Senate before the new Congress began, so it must be presented again in 2013.  This means that credit unions must continue to provide an annual privacy notice at this time.

The new Bill has been presented, and it has again passed the House.  Now it is back over to the Senate, in hopes that it will pass there as well.

If the Bill is passed into law, it would remove the requirement for credit unions to provide an annual privacy notice in certain conditions.  Generally speaking, a credit union would not need to provide an annual notice if its privacy policy is unchanged, and its current privacy policy does not trigger the need for an opt- out provision.  Essentially, members will not need to receive a notice unless there is a reason for them to take action.

This means a reduced burden upon credit unions, which is always a good thing.  It also means that those of us which are credit union members will get one less piece of mail, which we may consider to be irrelevant.  And, those of us that are compliance nerds won’t waste 20 minutes reviewing the document to ensure it is compliant, and to determine if any changes have been made.  Other than the postal service, everyone stands to gain if this Bill is passed.

Stay tuned to and for further updates.

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