As the year draws to a close, credit unions are wrapping up several year- end projects. And while many may be looking forward to the holidays, the Operations team is probably hoping year-end reporting runs smoothly so they aren’t spending New Year’s Eve at the credit union!
One annual project that a credit union may complete this time of year is the mailing of its privacy notice. A year ago, there was discussion about a Bill in Washington which would have removed the requirement that credit unions provide an annual notice, in many cases, if the policy was unchanged. However, the Bill lost momentum at some point, and was not passed into law. Unfortunately, this fell off of the radar of many credit unions and they were unsure if an annual notice was still required. I’ve received numerous calls within the last month, asking if the notice needs to be sent. And the answer is yes, credit unions should continue to provide the notice.
However, the CFPB announced on its Fall 2013 Regulatory Agenda, that it would be considering a rule which may mirror many aspects of the previous Bill.
Stay tuned to PolicyWorksllc.com for additional information as the CFPB moves forward. But, in the meantime, don’t forget to mail those notices!