Right to Financial Privacy (RPFA). Be Careful.

RISK LEVEL = HIGH

RFPA protects the personal financial privacy of federal credit union members by restricting access to the member's financial records.

A scenario: a local police officer comes into your office and tells you that he is investigating your member for his role in a fraud case involving the member's checking account. Just give him what he needs, right? Not so fast! The RFPA requires that the credit union obtain written authorization from the member, or secure from the government authority a subpoena or summons, a search warrant, a judicial subpoena, or a formal written request to release information about a member. Afraid to tell the cop you can't help him? Try this, it works for me . . . look around the room suspiciously, then quietly inform him that you can't help him because you believe he exists only in your imagination. He'll likely get scared and leave - at the very least, he'll go ask someone else.

In addition, policies and procedures for complying with the requirements of the Right to Financial Privacy Act (RFPA)are required. A good policy and due diligence to comply with the Act will keep you out of trouble. Compliance risk can occur when the credit union fails to implement the necessary controls to comply with RFPA; and Reputation risk can occur when members of the credit union learn of its failure to comply with RFPA. Risky business, that RFPA.