CUNA Regulatory Comment Call
November 19, 1999
Delivery of Electronic Periodic Statement Permissible if Member Agrees
- National Credit Union Administration (NCUA) requests comments on an interim rule that allows credit unions to deliver in electronic form periodic statement disclosures required by NCUA's regulations if the member agrees to this form of delivery.
- This rule was effective on November 26, 1999, and comments must be received by January 25, 2000. Please submit your
comments to CUNA by January 11, 2000, by fax at 202/371-8240 or by e-mail to CUNA's Assistant General Counsel Michelle
Profit at firstname.lastname@example.org.
Click here for a copy of the interim rule.
The Truth in Savings Act (TISA) requires NCUA to promulgate regulations substantially similar to those promulgated by the Federal Reserve within 90 days of the effective dates of the Federal Reserve's rule. Accordingly, NCUA has promulgated this rule, which is substantially similar to the Federal Reserve's TISA regulation.
- The rule does not permit a depository institution to deliver periodic statement disclosures electronically unless the consumer agrees to this method of delivery. The rule does not specify what is a valid agreement.
- The rule requires consumers to be clearly informed when they are consenting to electronic delivery of periodic statements and disclosures.
- The rule requires that the periodic statement be provided in a format that is clear and conspicuous, allows the display of visual text, and permits consumer retention of the statement.
- This rule applies only to periodic statement disclosures. Other disclosures required by TISA and Regulation DD may not be delivered in electronic form.
- Do you support this rule? Why?
- Is there any way that the interim final rule could be improved? Does NCUA need to clarify the type of notification credit unions must
send to their members regarding the electronic disclosure? Please explain.