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NCUA: Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice
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1.
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2.
Do you support the removal of Appendix B from Part 748 of NCUA’s regulations?
3.
Should the NCUA make any substantive changes to Appendix B if it is reissued as a Letter to Credit Unions?
4.
Do you foresee any potential risk that the state in which your credit union operates will enact new laws or regulations in response to the NCUA’s decision to reissue Appendix B as nonbinding guidance?
5.
The other federal banking regulators currently implement their own information security guidelines and incident response programs through codified appendices in their respective regulations. Should the NCUA proactively address any potential public misunderstanding about the rigor of credit union incident response guidelines relative to banks?