Credit Unions Update Disaster Record-Saving Guidelines
Published Date: 3/11/2026
Proposed Rule
Summary
The National Credit Union Administration (NCUA) is updating its rules to make it easier for credit unions to keep important records safe, especially during disasters. This update clarifies rules, updates definitions, and removes old appendices, helping credit unions protect member info without confusion. Comments on these changes are open until May 11, 2026, with no new costs expected.
Analyzed Economic Effects
5 provisions identified: 4 benefits, 1 costs, 0 mixed.
Appendices A and B removed
The NCUA proposes to remove Appendix A (Record Retention Guidelines) and Appendix B (Catastrophic Act Preparedness Guidelines) from 12 CFR part 749. Removing Appendix A ends the regulation's written recommendation that certain documents be kept permanently and is intended to reduce confusion and compliance burden for credit unions.
Flexibility to destroy older records
The proposed rule clarifies that credit unions may destroy older versions of vital records unless another law or regulation requires retention. The Board also will not set universal retention periods, leaving credit unions discretion to set retention schedules based on law, business needs, and statutes of limitation.
Electronic records log explicitly allowed
The proposal makes explicit that a credit union's records preservation log may be in electronic or other formats, clarifying that electronic storage and digital methods are permitted for vital records. The rule retains flexibility for credit unions to choose formats for preserving vital records.
Third-party vendor oversight required
If a credit union uses a third-party service provider to maintain vital records, the proposed rule states the credit union must maintain effective oversight of that provider. The heading for Sec. 749.3 is being amended to explicitly reference third-party service providers and oversight expectations.
Remove Appendix A reference in derivatives rule
The Board proposes to delete the citation to Appendix A in 12 CFR 703.105(d), which currently requires federal credit unions to retain derivatives reports in accordance with Appendix A. This technical amendment is intended to align other NCUA rules with the removal of Appendix A.
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