Compliance Blog

Apr 16, 2009
Categories: Privacy

Fryzel Speaks; Model Privacy Notice

Posted by Sarah Loats

NCUA Chairman Michael Fryzel made his first public speech since NCUA placed US Central and WesCorp into conservatorship. He addressed the attendants of the Texas Credit Union League's 75th Annual Meeting in Austin. Urging industry unity in resolving corporate issues, Fryzel stated in part:

“The Corporate Stabilization Plan is what we need for credit unions today. I need you to roll up your sleeves and in that great credit union tradition of grassroots activism, get it enacted into law so we can mitigate the cost to the system and allow credit unions to continue to serve their members. When this stabilization proposal becomes law, our job will not be finished. I have made a commitment to the Administration, to Congress and to you in the industry that NCUA would undertake a broad and comprehensive reform of the corporate system. We have initiated a rulemaking process that I promise will yield results.”


You can find NCUA's full press release here.

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Back in 2007 NCUA, along with the other federal financial regulators, issued a proposed rule, which would create a model privacy form in Appendix A of Part 716 of NCUA's regulations. Use of the model form would constitute compliance with the notice content requirements of sections 716.6 and 716.7. In developing the model form, the agencies decided to carry out two phases of consumer testing. The first phase involved form development research on an alternative format and the second phase to entail quantitative research on the effectiveness of the proposed alternative. The proposed rule included the phase one form development research. The phase two effectiveness research was to be conducted after the public comment period of the proposed rule.

Well, phase two is here, and the comment period for the proposed rule has been re-opened for 30 days to allow interested persons to comment on the additional quantitative testing documents. If you have any interest in how the consumer testing was conducted and the results you may find this to be a good read.