Navigating financial regulations is important for any credit union, especially when it comes to member privacy and communication. Two common areas of concern are the sharing of information to prevent fraud and the rules surrounding member outreach via text message.
When a credit union suspects fraud, it can share a member’s personal information with other financial institutions. This is allowed under Regulation P, 12 CFR 1016.15 (a), which permits the disclosure of information to “protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.” To manage this, a credit union should create clear policies, share only the necessary information on a case-by-case basis, and use secure communication channels. An alternative is to simply obtain the member’s consent to verify the transaction, which removes any ambiguity about what can be shared.
For text message communication, the Telephone Consumer Protection Act (TCPA) sets the rules. For any marketing messages, a credit union must obtain a member’s “express written consent,” which can be as simple as a checkbox on a form. While some exceptions exist for non-commercial and account-related messages (like fraud alerts), these still have limits on frequency and require the credit union to honor opt-out requests promptly. Furthermore, commercial texts can only be sent between 8:00 a.m. and 9:00 p.m., Monday through Friday.
For those who want to dive deeper into these regulations and their nuances, view the ViClarity Q&A with more detailed information.
The financial services industry’s greatest asset can also occasionally be its greatest threat: access to information that is immediately available, but questionable in its accuracy. In an era of instant gratification, access to factually accurate information requires wading through industry updates, which is both frustrating and difficult.
In this article, we provide some much-needed context to a few conversations currently occurring within the financial services industry.
On August 26, 2025, SBA delivered a letter to over 5,000 lenders to enforce the August 7 Executive Order (EO) 14331 (Guaranteeing Fair Banking for All Americans), which creates immediate compliance obligations for SBA-approved lenders, including credit unions.
The EO alleges de-banking has occurred across our industry based on political affiliations, religious beliefs, and lawful business activities.
For more information, email Heather Line.
Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:
Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!
Additionally, other League-member compliance resources include:
For more information, email Lisa Quaranta.
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