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Cornerstone Urges CUs to Support CFPB's Proposal to Permit CUs to Eliminate Mailing Annual Privacy Notices
Friday, July 11, 2014 7:00 AM

The Consumer Financial Protection Bureau has issued a comment proposal that will amend Regulation P [Privacy of Consumer Financial Information] to permit credit unions that do not participate in information sharing or are otherwise required to issue an opt-out notice, to distribute their annual privacy notices through their credit union website rather than mailing the notice to each member. This is a rare instance where CFPB is proposing to reduce regulatory burdens and save credit unions time and money, so Cornerstone is encouraging credit unions to support the proposal.  

In order to use the proposed exemption from mailing the annual privacy notice, the credit union must:

  • Indicate on another mailing, at least annually, that the notice is available on the credit union’s website
  • Not have changed its privacy notice in the last year, or since the last mailing of the notice
  • Provide for a toll-free number, where a member may request a mailed notice
  • Provide a mailed notice on request,
  • Make the notice available on the credit union’s website without need for a login or password, and
  • Use the Model Annual Privacy Notice Form included in the Appendix to Regulation P

The comment period for the proposal ends July 14, and Cornerstone encourages all credit unions to submit a comment letter in support of the proposal.  Cornerstone anticipates that the majority of member-credit unions would fall within the exemption, and would greatly benefit. This proposal has the potential to save your credit union both labor and paper costs associated with sending out this notice each year, as well as saving our members from another piece of unwanted mail.

Unfortunately, CFPB does not use an email format for commenting.  Please submit your comments via the website or regular mail as instructed below:

To submit via the internet, go to www.regulations.gov, and search for the proposal using either the docket number CFPB-2014-0010 or the code RIN 3170-AA39. Please note that the CFPB encourages web submissions because of mail delays.

To submit via mail, please address to letters to:

Monica Jackson
Office of the Executive Secretary
Consumer Financial Protection Bureau
1700 G Street NW
Washington, D.C. 20552

In the subject line, make sure to also include the agency name (CFPB) and the docket number CFPB-2014-0010 or Regulatory Information Number RIN 3170-AA39.

To view a copy of the regulations in the Federal Register, please follow this link.

If you have any questions about submitting a comment letter, or on how to write one, please contact Suzanne Yashewski, at (512) 853-8516. Please also forward a copy of any submitted letters to syashewski@cornerstoneleague.coop.