Credit union regulator updating consumer complaint records system to support pre-exam planning

The federal regulator of credit unions plans by month-end to update its consumer complaint records system to reflect a change in the way examination personnel access and retrieve records when conducting required pre-exam planning reviews of consumer complaints.

The update, detailed in a notice slated to appear in Wednesday’s Federal Register, is out for comment until April 30. It will take effect on that date unless comments received lead to changes.

“The change in access will improve the effectiveness and efficiency when examiners conduct the required pre-exam planning review of consumer complaints,” the notice states. “Examiners may securely view consumer complaints, credit union responses, supporting documentation about complaints, and consumer protection violations concerning the credit unions in their assigned region.”

The system of records, called NCUA-12 Consumer Complaints Against Federal Credit Unions System, collects and maintains consumer complaints against credit unions received and processed by the NCUA Consumer Assistance Center. The center is housed within the agency’s Office of Consumer Protection (previously called the Office of Consumer Financial Protection and Access, as this update shows).

The agency’s consumer complaints records system supports the NCUA’s supervisory oversight and enforcement responsibilities to receive and respond to consumer inquiries, complaints and other communications from the general public, credit unions and other state and federal government banking and law enforcement agencies regarding federal consumer protection laws, regulations and credit union activity.

Records maintained include correspondence and records of other communications between the NCUA and the person making the complaint or submitting an inquiry, including copies of supporting documents and contact information submitted by that individual. The system may also contain regulatory and supervisory communications between the NCUA and the federally insured credit union in question, as well as relevant intra-agency or inter-agency memoranda or correspondence.

The notice also details what are “routine uses” of the records, record access procedures, “contesting” procedures for seeking amendments to records, and “notification” procedures for individuals seeking to find out whether this records system contains information about them.

The same notice regarding the consumer complaints records system also notes the agency is rescinding another records system – NCUA-5, Unofficial Personnel and Employee Development/Correspondence Records – since the records involved are already covered by other systems within the Office of Personnel Management. This too is set to take effect April 30.

NCUA notice, Privacy Act systems of records