The U.S. Government Accountability Office (GAO) released a report this week showing that, for the most part, privately insured credit unions are doing an excellent job keeping up with regulations. But, according to the GAO report, there appears to be some confusion about Regulation I disclosures – those that relate to disclosure information, format, and advertising.

The GAO's "Report to Congressional Committees" found that credit unions were largely in compliance with the CFPB's requirement for disclosures at each station or window where deposits are normally received. However, according to the report, "seven of the 17 credit unions we visited that had drive-through windows did not have disclosures at the window."

"While Regulation I states disclosures are needed at each station or window where deposits are normally received, it does not specifically cite drive-through windows," the report stated.

According to the CFPB, "a plain reading of Regulation I would include a drive-through window."

The GAO found in its report that privately insured credit unions surveyed, complied with the CFPB's requirement that the credit union disclose, at the physical branch, the fact that it is not federally insured.

On the other side of that, eight of the 36 credit unions reviewed for this report, did not include that disclosure in advertisements, websites or printed materials.

"Without clear disclosure requirements, state credit union supervisors and credit unions may not be consistent in how they interpret disclosure requirements" and some consumers may not be properly informed, according to the findings in the report. 

The GAO recommended that the CFPB issue better guidance for privately insured credit unions concerning advertisements, website and drive-through disclosures.

The entire report can be found here.  

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Michael Ogden

Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.