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|Clarissa Martin, Research and Information Consultant for the California and Nevada Credit Union Leagues|
The overall notice consists of two parts: a short notice and a long notice. They should be in the same language as the offer of credit or insurance.
The Fair Credit Reporting Act (FCRA) allows creditors to obtain credit reports for transactions not initiated by the member called “pre-screen offers of credit.” When a credit union engages in pre-screening, it is required to provide a notice to the consumer with their right to opt out of pre-screened solicitations for credit or insurance.
MLA DATABASE FEB. 15 DEADLINE
updated 02/09/16 08:00 AM
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Credit unions seeking a safe harbor under the Department of Defense’s (DoD) Military Lending Act (MLA) final rule will have two new options come Oct. 3, 2016: 1) A credit union may verify a borrower’s status on the DoD’s database, or 2) a credit union may use a consumer report obtained from a nationwide consumer reporting agency to determine whether a borrower is a “covered borrower.” Credit unions interested in utilizing the first option have until Feb. 15, 2016 to notify the Defense Manpower Data Center (DMDC) of their intent. This may be done by emailing the MLA helpdesk at email@example.com.
CA PRIVACY NOTICES STILL REQUIRED
updated 02/02/16 08:35 AM
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The FAST Act made changes to federal annual privacy notice requirements. However, it did not change California privacy notification requirements, which are applicable to all financial institutions doing business in California. California state annual privacy notifications are still required, depending on what information is shared and with whom.