NCUA updating its consumer complaint records system; comments due Sept. 14

The federal regulator of credit unions is making some changes to its consumer complaints records system, including a change allowing information to be shared with other agencies when necessary to respond to a data breach.

The proposed changes in the National Credit Union Administration (NCUA) records system, Consumer Complaints Against Federal Credit Unions (NCUA-12), have been reviewed by the Office of Management and Budget (OMB) and are scheduled to take effect Sept. 14. Comments will be accepted until that date, and the changes will go forward “unless comments are received that would result in a contrary determination,” the agency said in a recent Federal Register notice.

NCUA says this records system collects and maintains consumer complaints against federal credit unions that are received and processed by the NCUA Consumer Assistance Center. Changes proposed are as follows:

  • A change in access is proposed to improve effectiveness and efficiency when examiners conduct the required pre-exam planning review of consumer complaints. “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,” according to the notice. NCUA is also changing the office system owner’s name due to a reorganization that resulted in the NCUA Office of Consumer Financial Protection and Access, which houses the Consumer Assistance Center, being renamed the Office of Consumer Protection.
  • One routine use is being added to the list of standard routine uses for this system. This additional routine use will facilitate the sharing of NCUA’s information with another agency in its efforts to respond to a breach. It will ensure that NCUA meets the requirements of OMB M-17-12, Preparing for and Responding to a Breach of Personally Identifiable Information,” the notice says.
  • The agency is revising authorities for system maintenance to reflect “specific programmatic authority for collecting, maintaining, using, and disseminating the information,” NCUA wrote.

NCUA has also modified the format of NCUA-12 to align with guidance in OMB Circular A-108, Federal Agency Responsibilities for Review, Reporting, and Publication under the Privacy Act.

NCUA notice of a modified system of records; notice of modified standard routine uses

OMB M-17-12, Preparing for and Responding to a Breach of Personally Identifiable Information

OMB Circular A-108, Federal Agency Responsibilities for Review, Reporting, and Publication Under the Privacy Act

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