Q: Are corporate credit unions covered by the Red Flags Rules and Guidelines?
A: Yes. The term “corporate credit union” is defined in 12 C.F.R. § 704.2 and means a credit union chartered under Federal or state law that:
receives shares from and provides loan services to credit unions;
is operated primarily for the purpose of serving other credit unions;
is designated by the NCUA as a corporate credit union;
limits natural person members to the minimum required by state or federal law to charter and operate the credit union; and
does not condition the eligibility of any credit union to become a member on that credit union’s membership in any other organization.
As described above in II.A.2, the Red Flags Rules and Guidelines apply to “financial institutions” as defined in the FCRA, regardless of whether they hold consumer transaction accounts. Therefore, all credit unions, including corporate credit unions, are covered by the Red Flags Rules and Guidelines.