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).
- 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.