Posted by Anthony Demangone
- I'd inventory each copier your credit union owns. Then contact the service provider or read the owner's manual to see if it stores all of its copies digitally.
- If the copier does store all of the copies digitally, I'd want to know my options. First, do you need that function? In my 6 years at NAFCU, I never needed to retrieve a copy from a copier's hard drive. If your credit union doesn't need that function, see if you can turn it off. If you do need that function, find out how you can periodically purge that data. I mean really purge it - so that an identity thief with hi-tech capabilities can't recover your member data. (I mention this because I watch NCIS. The characters on that wonderful TV series always retrieve data from computers after the criminal du jour thought he had wiped the hard drive clean.)
- What happened to your old copiers? When you replace an old copier, do you have procedures to clean its hard drive? Or does your servicing company do this?
- Here's the tough question - if you can't answer question three in the affirmative, would you be able to track down old copiers? Perhaps the company that services your copiers can help you.
- Why stop at copiers? You have fax machines. Computers, both of the desk an lap varieties. Do you give them away to staff or trade them in? Either way, are those hard drives clean?
Proposed Rule – Section 701.21(c) of NCUA’s Rules and Regulations, Short-term, Small-dollar Loans
The proposed rule would amend NCUA’s general lending rule to enable more federal credit unions to offer short-term, small amount loans. This amendment would allow federal credit unions to charge an APR of 28 percent, which is higher than the maximum APR permitted under the general lending rule. (The proposal details how NCUA can do this legally, under the Federal Credit Union Act.) Additionally, credit unions would be able to charge a maximum application fee of $20. The proposed rule also identifies “best practices” federal credit unions should incorporate into their individual short term, small amount lending programs.
The proposal sets a minimum maturity of one month and a maximum maturity of six months for these loans. The loans must be for at least $200 and no more than $1,000. Credit unions may only make one such loan at a time to a member and no more than three loans in a six month period may be made to the same member. Further, the rule prohibits credit unions from rolling over the loan. In order to ensure the loans to not threaten safety and soundness, credit unions would be required to include in their written lending policies a cap on both the total number and total dollar amount of STS loans.
The proposed rule will be published in the Federal Register with a 60-day comment period.