Exception for providing annual privacy notices
outlined in summary

Jan. 27, 2016 -- Federal examiners will only expect annual privacy notices to be provided if a credit union does not meet new requirements outlined in a letter to credit unions which was sent this week to all federally insured credit unions by NCUA.

NASCUS has developed and published a summary of the letter (available to members only).

“If you have not changed your credit union’s privacy policy since your last annual privacy notice, you may not have to send another privacy notice this year—as long as you meet the conditions described in this letter,” states LTCU 16-CU-03, signed by NCUA Board Chairman Debbie Matz. The letter notes that those requirements include:

  • A credit union’s policies and practices have not changed since it provided its most recent privacy notice to consumers; and
  • A credit union shares nonpublic personal information with nonaffiliated third parties only in accordance with requirements for certain existing GLBA exceptions (see the NASCUS summary for additional details).

The exception from providing the privacy notice is the result of legislation passed late last year that creates a new exception (in certain circumstances, as the NCUA letter notes) to the statutory requirement that credit unions provide consumers with annual privacy notices.

LINKS:
NASCUS Summary of LTCU 16-CU-03 (members only)
Text of LTCU 16-CU-03