Are credit union service organizations (CUSOs) covered by the Red Flags Rules and Guidelines?
CUSOs, according to the Federal Credit Union Act, provide “services which are associated with the routine operations of credit unions” and are “established primarily to serve the needs of its member credit unions, and whose business relates to the daily operations of the credit unions they serve.” 12 U.S.C. ยงยง 1757(5)(D), (7)(I). A CUSO that is a “creditor” under the FCRA is covered by the Red Flags Rules and Guidelines issued by the FTC. *** The WHO has officially declared a pandemic. What does this mean for compliance? The WHO lists the risk of a pandemic with phases, numbered one through six. We’re now at WHO pandemic phase six. Some credit unions use the WHO stages to trigger different parts of their pandemic plan. You may want to check your pandemic plan to see what phase 6 triggers.
