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NCUA Board Member Tanya Otsuka Statement on the Advance Notice of Proposed Rulemaking on Part 749, Records Preservation Program

April 2024
NCUA Board Member Tanya Otsuka Statement on the Advance Notice of Proposed Rulemaking on Part 749, Records Preservation Program

As Prepared for Delivery on April 18, 2024

Thank you, Kelly and Matt, for your presentation and all the staff’s work on this ANPR. Sound record retention practices, although not a topic often discussed, are critical to ensuring the continuity and longevity of credit unions and the credit union system. The purpose of these important rules and guidance is to make sure that credit unions, especially smaller ones, can continue running in the event of a natural disaster or some other unforeseeable event. The pandemic and its aftermath showed us how important it is for credit unions to have prudent business continuity practices and fail safes.

Additionally, as the frequency and intensity of weather-related events – like wildfires, hurricanes, and floods – and cyber-related security threats continue to increase, it is even more important that the NCUA is clear about what is needed to ensure credit unions can withstand risks to their business operations, so they can ultimately continue to serve their members when they need it the most.

To that end, we strongly encourage credit unions, members, advocates, and other stakeholders to weigh in on what current practices are working or not and where the NCUA can provide clearer direction on which records should be retained, for how long, in what format, and for what purpose. As institutions move away from paper filing systems and explore cloud computing and other electronic means of storing data, this rule is ripe for updating.

Credit union members should also feel empowered to provide their experiences dealing with credit unions during the pandemic, natural disasters, or other events that caused lapses in their credit union’s continuity. Members have a unique perspective on how well their credit unions enabled their members to access their funds quickly in the case of an emergency.

Credit unions exist to serve their members and their broader community, which is also central to the NCUA’s work. Getting feedback from the public is an important step towards making sure that credit unions are well-prepared to continue serving their members, and I support issuing the ANPR. Thank you.

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