Most credit unions know our system, CUOnline, as where they file their Call Reports. But it also plays a critical role in our response during disasters like the ones we saw with Hurricanes Harvey, Maria, and Irma and the California wildfires, among others.
The NCUA and our partners on the federal and state level rely on information found in the Credit Union Profile during a disaster. Our Consumer Assistance Center, which handles questions from credit union members and the public, will also use information found in the Profile to provide members and consumers with contact information, branch locations and other important information. It is essential that the Profile information found in CUOnline be accurate and current, so we can carry out an effective disaster response.
Yet, during the disasters in the second half of 2017, we found the Profile information of some credit unions was not always accurate or complete, and this hindered our ability to respond to requests for assistance or to provide accurate information to our federal and state partners. Some of these errors may have been the result of credit unions not understanding the terms used in the Profile form, while other errors may have been due to credit unions not realizing the importance of the information or not updating critical information before a disaster, among other reasons.
The NCUA requires credit union management to update its Credit Union Profile information in detail, at least quarterly, to ensure its accuracy. However, prior to an anticipated disaster like a hurricane, credit unions in the potentially affected area should review their emergency contact information in their Profiles to make sure it is up-to-date. It’s also important to list multiple emergency contacts in the Profile to ensure the NCUA or a credit union’s state supervisory authority can reach someone to determine the credit union’s operational status, share information on state and local responses to the emergency, and provide assistance if necessary.
Based on the lessons learned from responding to disasters in 2017, we recommend that all credit unions review and update their Profile information related to the following items:
- Your primary and secondary emergency contacts should be officials who have decision-making authority. Their contact information should include several ways to reach these individuals, including multiple phone numbers and emails. This information will not be shared with the public.
Locations and Facilities:
- List only your main office or headquarters as a “corporate office.” Only one location can be the corporate office.
- List ATM-only sites as “Other.”
- List sites used only for disaster recovery (meaning no other functions) as “Other.”
- List each location only once. If there is more than one function performed at a location, choose all of the appropriate functions from the options available for that location.
- Ensure all physical addresses, including branches, your corporate office and ATMs can be found on widely used mapping tools like Google Maps, MapQuest and Waze.
- List suspended or planned locations, and other non-operational sites as “Other” or as “Vacant Land.”
Lastly, your members need accurate information as well. Before, during, and after a disaster, credit unions should update information on their websites regularly and use a variety of mechanisms, like social media—even text messages—to communicate operational information to their members. Also, you should ensure these systems and your staff can handle increased usage, traffic and information requests from your members during and following a disaster.
During a disaster, accurate information is essential, not only to regulators, but also to your members. Ensure that your CU Profile information is accurate and up-to-date. This will improve our ability to respond efficiently and effectively, and it will help put your members at ease.