General Questions
Where can I find best practices related to catastrophic act preparedness?
Credit unions can reference NCUA’s business continuity resources on its Catastrophic Act Preparedness Information webpage.
Close and return to topDo NCUA regulations require credit unions follow the resources provided on NCUA’s Catastrophic Act Preparedness Information webpage linked above?
No.
The resources provided are not regulatory requirements. They are offered as best practices for a credit unions to consider when developing or assessing its Catastrophic Act Preparedness Program.
What are vital records?
Vital records are the most recent and current versions of the records a credit union needs to restore essential member services. These records are:
- 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
- Contains information sufficient to enable the credit union to locate each member, such as address and telephone number
- A financial report, which lists all the credit union's asset and liability accounts, current as of the most recent month-end
- Bank reconcilements, current as of the most recent month-end
- A list of the credit union's accounts at financial institutions, insurance policies, and investments, including related contact information, current as of the most recent month-end
- 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 at its discretion.
Close and return to topHow should credit unions think about which records to preserve?
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 to determine which records are required to restore vital member services in a catastrophic event.
Close and return to topDoes this rulemaking affect other record keeping requirements?
Yes.
This final rule removes the record keeping requirement in 12 CFR 703.105 (d), which only applied to federal credit unions. The other NCUA regulations; applicable laws, such as those imposed by the state; and additional regulations that establish record keeping requirements are unaffected by this rule change.
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