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 2019-12-11 14:00:00 2019-12-11 14:00:00 Reg CC – Common Compliance Issues and Best Practices In 2018, the Consumer Financial Protection Bureau and the Federal Reserve Board overhauled various portions of Regulation CC to better align the Regulation to the realities of check processing in the 21st century. You should understand the nuances behind these recent changes to ensure both (1) that your check-processing program complies with the requirements, and (2) that your check processing program is modernized to take advantage of the updates. This webinar will explain these changes, as well as subsequent updates and some Regulation CC compliance issues that credit unions should keep on their radar. Key Takeaways: Review modifications to check collection and return requirements for electronic checks Discuss extension of Regulation CC’s check warranties to checks collected electronically Identify new warranties and indemnities related to checks collected and returned electronically as well as electronically created items Learn about additional updates, including the presumption of alteration & adjustments to funds availability requirements, withdrawal exceptions, civil penalty amounts, etc. Walk through the potential use of deposit holds to help combat fraud Purchase 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 December 11, 2020Already registered? Go to the Online Training Center to view. Who Should Attend? NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) Compliance staff Risk management staff Audit staff Legal staff 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 modifications to check collection and return requirements for electronic checks. Discuss extension of Regulation CC's check warranties to checks collected electronically. Identify new warranties and indemnities related to checks collected and returned electronically as well as electronically created items. Learn about additional updates, including the presumption of alteration & adjustments to funds availability requirements, withdrawal exceptions, civil penalty amounts, etc. Walk through the potential use of deposit holds to help combat fraud. 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 Federal 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: NCCO, NCRM, CPE
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