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Credit unions are constantly entering into agreements with third-party vendors ranging in criticality from vendors that implement a new core processor to vendors that provide custodial services. Regardless of the vendor, credit unions have a regulatory obligation to protect confidential member information. This regulatory obligation has come under increased scrutiny by the NCUA considering the ever-present threat of cybersecurity data breaches. Therefore, in addition to credit unions’ regulatory obligation to maintain the security and confidentiality of member information, it is also imperative for credit unions to address the data breach threat by ensuring there are adequate protections incorporated into their vendor agreements to avoid potential liability resulting from unauthorized access or use of their confidential information.

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