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|Arnold Ramirez, Research and Information Consultant for the California and Nevada Credit Union Leagues|
According to Regulation E §1005.20, there are certain conditions that must be met for an issuer or seller of a general-use prepaid card which determine whether an expiration date may be applied.
Before a general-use prepaid card is purchased, the issuer or seller must disclose to the consumer the information about dormancy, inactivity, service fee, expiration date, and the toll-free telephone number. If the issuer or seller has a website, it must also disclose that site so the consumer can obtain fee information.
These disclosures must be made on the card. A disclosure made in an accompanying terms-and-conditions document—or on the packaging surrounding a certificate or card, or on a sticker or other label affixed to the certificate or card—does not constitute a disclosure on the certificate or card.
The fees—and terms and conditions of expiration—that are required to be disclosed prior to purchase may not be changed after purchase.
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.
CUSOs TO REGISTER WITH NCUA REGISTRY
updated 01/26/16 10:07 AM
NCUA Hosts Webinar on New System
In a letter sent to credit unions, credit union service organizations (CUSO) have 60 days to register with the National Credit Union Administration’s (NCUA) CUSO Registry, the new online system for CUSOs to report their operational and financial information directly to the agency. The registration period begins Feb. 1 and ends March 31.