ID Theft Red Flags FAQ IIA8 – Are credit union service organizations (CUSOs) covered by the Red Flags Rules and Guidelines?

Compliance > Lending > FCRA
Q:  Are credit union service organizations (CUSOs) covered by the Red Flags Rules and Guidelines?
 
A:  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. §§ 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.
 
 
ADDITIONAL INFORMATION:
This information was obtained from the Interagency FAQs for Identity Theft Red Flags and Address Discrepancies - https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20090611a1.pdf
 

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