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New CUNA Checklist for Privacy Notice Opt-Outs
Monday, April 11, 2016 6:35 AM

Credit unions confused by the in-progress changes to annual privacy notice requirements have a new resource, courtesy of the Credit Union National Association, which has developed a privacy notice opt-out checklist.

The checklist is a comprehensive resource intended to assist credit unions until the rule is finalized. Developed by CUNA Senior Federal Compliance Counsel Colleen Kelly, the list asks credit unions about the sharing of nonpublic personal information with third parties and if those third parties are “affiliates” of the credit union. The list lays out the requirements for financial institutions that disclose nonpublic personal information with nonaffiliated third parties.

Those institutions are required to:

  • Provide an initial notice to the member;
  • Provide an opt-out notice to the member;
  • Give the member a reasonable opportunity to opt out before disclosing the information to nonaffiliated third parties, or if the member opts out, do not share the information; and
  • Provide this notice annually.

These requirements do not have to be met unless one of 17 exceptions apply, as listed on CUNA’s checklist.

CUNA’s Compliance Community contains CUNA’s CompBlog, as well as a discussion board and numerous other resources and networking opportunities for credit union compliance professionals around the world.