Disclosure requirements for multiple members on the same account

The NAFCU Compliance Team has received a few questions recently on providing disclosures when there is more than one member on an account. Essentially, the question is: If there are multiple members on one account, does [insert regulation of your choice here] require a credit union to provide the required disclosure to each member?

For most of the disclosures credit unions are required to provide, such as account opening and change in terms, the answer is no. However, some of the regulations provide special rules for certain disclosures. The chart below goes through some of the various regulations and indicates whether notice to any one member is sufficient or whether multiple disclosures are required. This NAFCU blog discusses the adverse action notice requirements for joint applicants under the FCRA.


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