Rarely does a week go by when we do not receive a call from a credit union regarding potential elder abuse. Recently, the number of calls regarding the legal, moral and ethical means to collect a credit union debt from a deceased member's estate has been increasing. With those credit unions that have an "aging" membership, these issues become more and more paramount.

With little fanfare and very little press coverage, the Federal Trade Commission (FTC) recently published a "Statement of Policy Regarding Communications in Connection with the Collection of Decedents' Debts." The final policy statement is effective Aug. 29, 2011 and impacts all companies that are subject to the Fair Debt Collection Practices Act (FDCPA).

Generally speaking, if a credit union is conducting its collection efforts "in house," it is probably not subject to the FDCPA, but many credit unions utilize CUSOs, collection agencies or collection attorneys, and all of those entities are generally subject to the FDCPA. So please be on alert.