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Compliance Notifying members under Reg E
WASHINGTON (5/31/11)--Member notifications and other disclosures are addressed in this month’s Credit Union National Association (CUNA) Compliance Challenge. In the Challenge, CUNA recommends that credit unions inform members who do not wish to be sent monthly account statements that other notification options exist. They include electronic statement delivery via e-mail, the option of picking up their paper statements at their credit union, or delivery to an alternate address or P.O. box. Credit unions may not simply cease sending statements; they are required to provide statements to their members by Regulation E. Those statements must be sent in each monthly cycle that a direct deposit, ATM transaction, debit card purchase, or other electronic transfer occurs. However, the frequency can be scaled back to four times per year if these transactions do not occur. Credit unions may also stop sending notifications for accounts that have become inactive, CUNA noted. ATM-related disclosures that are required by Reg E were also covered this month. According to CUNA, credit unions do not need to disclose on their own ATMs that their members may be charged fees for using another institution’s ATM. Disclosures for so-called “foreign fees,” which are charged by the account-holding institution when a credit union member uses an out of network ATM, are disclosed in the account agreement and appear on the member’s monthly account statement. For more of this month’s Compliance Challenge, use the resource link.


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