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As the Bureau of Consumer Financial Protection reviews its data collection practices, NAFCU is seeking feedback on how to reduce credit unions' burdens while ensuring adequate data collection. The association – a leading advocate for strong national data security standards – has previously commented on risks associated with the bureau's previous data handling policies.

Last month, the bureau issued a report addressing concerns raised by the Government Accountability Office (GAO) and the bureau's Office of Inspector General. The bureau is now in the process of collecting stakeholder feedback on the report's findings and the bureau's practices.

In response to the bureau's request for information, NAFCU issued a Regulatory Alert to members Monday and would like to know:

• if the bureau's data collection practices protect member privacy;

• if the bureau should limit its data collection scope to items expressly required by law;

• if there are alternative data sources the bureau could utilize that would meet its needs while reducing credit unions' reporting burdens;

• if the existing data governance framework establishes adequate safeguards to avoid unnecessary or burdensome data collections; and

• if the bureau's data collections are aligned with how credit unions manage data or utilize technology.

In the past, NAFCU has commented on risks associated with the bureau's previous data handling policies, especially in relation to data collection efforts under the Home Mortgage Disclosure Act (HMDA) and the consumer complaint database. The association has also urged the bureau to exempt credit unions from any future rulemaking related to data collection and reporting on small business lending.

Credit unions can submit comments to NAFCU on the bureau's data collection practices through its Regulatory Alert until Dec. 7; comments are due to the bureau Dec. 27.