Catastrophic Act Preparedness FAQs

Credit unions can reference NCUA’s business continuity resources on its Hurricane and Disaster Information webpage.

No.

NCUA provides resources that credit unions may find useful in developing or evaluating their disaster preparedness plans and business impact analysis.

Vital records are the most recent and current versions of the records a credit union needs to restore vital member services. These records are:

1. A list of share, deposit, and loan balances for each member's account as of the close of the most recent business day that:
   • Shows each balance individually identified by a name or number,
   • Lists multiple loans of one account separately, and
   • Contains information sufficient to enable the credit union to locate each member, such as address and telephone number.
2. A financial report, which lists all of the credit union's asset and liability accounts, current as of the most recent month-end.
3. Bank reconcilements, current as of the most recent month-end.
4. A list of the credit union's accounts at financial institutions, insurance policies, and investments along with related contact information, current as of the most recent month-end.
5. Emergency contact information for employees, officials, regulatory offices, and vendors used to support vital records.

A credit union may classify additional records as vital and maintain older versions of any vital records as it determines necessary.

Credit unions should consider all the essential financial services it provides to its members, such as member access to their accounts, share withdrawal and deposit facilities, and loan payments and disbursements, and determine which records would be required to restore those vital member services in event of a disaster.

Yes. This final rule removes the record keeping requirement in 12 CFR 703.105 (d) that only applied to federal credit unions. No other record keeping requirements in other parts of NCUA’s rules or other applicable laws or regulations are affected by this rule change.