It can apply only if the firm maintains customer information concerning fewer than 5,000 consumers, and it removes only four listed duties. Citation: 16 CFR 314.6.
Primary source: FTC Safeguards Rule business guidance
Does the under-5,000-consumer exemption apply to a non-federally insured credit union?
Details
Many credit unions exceed 5,000 consumers through member and former-member records. A very small institution should still document the count because 16 CFR 314.6 is limited. The firm should document the count method, because old files, leads, former customers, and retained records can matter.
Primary source: FTC Safeguards Rule business guidance.
FAQ
Does the under-5,000-consumer exemption apply to a non-federally insured credit union?
It can apply only if the firm maintains customer information concerning fewer than 5,000 consumers, and it removes only four listed duties. Citation: 16 CFR 314.6.
What is the data-flow issue for a non-federally insured credit union?
Member data lives in core processing, online banking, loan files, card systems, ACH and wire systems, shared-branching tools, call-center notes, and vendor portals. The WISP should map third-party core and online banking providers with contract oversight.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.