Questions on truncating account numbers? NAFCU Compliance Blog has answers
In the wake of historic data breaches, NAFCU has received questions from member credit unions on the regulatory requirements related to truncating account numbers on periodic statements in order to protect members' financial information. NAFCU's Reginald Watson explains requirements for doing so under Regulation E in a new NAFCU Compliance Blog post.
"Surprisingly, there is not a lot of federal regulatory guidance with respect to the truncation of account numbers on statements and notices given to members," writes Watson. "Section 1005.9(a)(4) of Regulation E allows credit unions to truncate account numbers on receipts available at electronic terminals, such as ATMs."
Watson, NAFCU's regulatory compliance counsel, goes on to explain that the Federal Reserve in the preamble of Regulation E sought to "protect consumers and financial institutions against fraudulent withdrawals" by allowing account numbers to be truncated on ATM receipts. However, Watson says that the regulation seems to require credit unions to disclose the entire account number on a periodic statement.
"In this modern age where the risk of cybersecurity theft competes with the manual fraud risk of a stolen ATM receipt, it seems that protecting the member's personal information on an electronically available periodic statement is just as important," Watson argues.
Read the full post and access additional resources on the issue here.
Add to Calendar 2019-08-20 14:00:00 2019-08-20 14:00:00 Overdraft Litigation Risk: Pitfalls and Effective Compliance Tools In recent years, a host of plaintiffs’ firms have targeted credit unions who have charged overdraft fees or insufficient funds fees. Those firms have also aggressively marketed to credit union members via targeted social media campaigns and websites, all with the goal to collect enough consumers for various class actions. Credit unions are also receiving demand letters directly from these firms on behalf of credit union members. Case law on the topic is evolving and not always consistent. In this webinar, we’ll discuss the applicable regulations associated with overdraft fees, and how to identify and analyze potential credit union risks. Regulation E provides the applicable guidance for the assessment of overdraft fees and the like and provides a model form with commentary. Key Takeaways: Review Regulation E Analyze model disclosures Discuss current case law Understand how to protect your credit union from overdraft litigation Register Now $295 Members | $395 Nonmembers (Additional $50 for CD) One registration gives your entire team access to the live webinar and on-demand recording until August 20, 2020Already registered? Go to the Online Training Center to view. Who Should Attend? NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) Risk staff Compliance staff Credit Union attorneys Education Credits NCCOs will receive 1.5 CEUs for participating in this webinar. NCRMs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: Review Regulation E. Analyze model disclosures. Discuss current case law. Understand how to protect your credit union from overdraft litigation. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Regulatory Ethics - Technical National Association of Federally-Insured Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: CPE, NCCO, NCRM
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