Privacy Policy

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Privacy Policy
Northwestern Federal Credit Union recognizes its responsibility to protect the privacy of member nonpublic personal informaton. The purpose of this policy is to set forth the guidelines under which such informaton may be shared with third partes. It is the intent of the Credit Union and any of its affiliates to abide by all applicable laws and regulatons governing the privacy of nonpublic personal informaton including the Consumer Financial Protecton Bureau (CFPB)’s Privacy of Consumer Financial Informaton rule (Regulaton P), issued to implement the provisions of the Gramm-Leach-Bliley Act and the Right to Financial Privacy Act.
The Credit Union is commited to safeguarding the security of confidental business informaton of the Credit Union and personal, non-public member informaton. Such informaton includes any informaton regarding members’ accounts, operatons of the Credit Union, development of new services, internal marketng informaton, all computer transactons, and all similar informaton related to the business of the Credit Union. Any such informaton or transactons must remain confidental unless disclosure is authorized by the member or required by law.
Proprietary informaton about the Credit Union shall not be disclosed to any third party unless authorized by the Board or Credit Union management. All employees and officials shall protect the privacy of member informaton and shall strictly adhere to the Credit Union’s Privacy Policy and practces and all applicable law.

DEFINITIONS. For the purpose of this privacy policy, the following definitons shall apply.
A. Consumer. A consumer is an individual, or such individual’s legal representatve or personal representatve, who has obtained a financial product or service from the Credit Union for personal, family or household purposes or for whom the Credit Union is actng as fiduciary. A consumer is not necessarily a member of the Credit Union.
B. Member. A member is a consumer with whom the Credit Union has, or has had in the past, a contnuing relatonship where the Credit Union has provided one or more financial products or services for personal, family or household purposes. Examples:
i. Members as defined the Credit Union’s bylaws;
ii. A nonmember joint accountholder held with a member;
iii. A former member.
iv. A nonmember who has a loan that the Credit Union services;
v. A nonmember who has an account with the low-income designated Credit Union; and
vi. A nonmember who has an account in a federally-insured state-chartered Credit Union pursuant to state law.
C. Nonpublic Personal Informaton. Personally identfiable financial informaton and any list, descripton, or other grouping of consumers (and publicly available informaton pertaining to them) that is derived without using any personally identfiable financial informaton, other than publicly available informaton. Nonpublic personal informaton does not include publicly available informaton.
D. Personally Identfiable Financial Informaton. Any informaton provided to the Credit Union by a consumer to obtain a financial product or service, or as a result of a transacton with the consumer. Examples:
i. Informaton a consumer provides to the Credit Union on an applicaton to obtain membership, a loan, credit card or other financial product or service;
ii. Account balance informaton, payment history, overdraft history, and credit or debit card purchase informaton;
iii. The fact that an individual is or has been one of the Credit Union’s members or has obtained a financial product or service from the Credit Union;
iv. Any informaton about a consumer if it is disclosed in a manner that indicates that the individual is or has been a member of the Credit Union;
v. Any informaton that a consumer provides to the Credit Union or that the Credit Union or its agent otherwise obtains in connecton with collectng on a loan or servicing a loan;
vi. Any informaton the Credit Union collects through an Internet “cookie” (an informaton collectng device from a web server); and
vii. Informaton from a consumer report.

COLLECTION OF INFORMATION. In the course of delivering products and services, the Credit Union obtains nonpublic personal informaton, either directly from the member or from outside sources. This nonpublic personal informaton is used to comply with federal and state laws and regulatons, to provide effectve member service and to inform members of products and services which may be of interest to the member.

MAINTENANCE OF ACCURATE INFORMATION. The Credit Union will exercise reasonable cauton in the gathering and maintenance of informaton to ensure its accuracy. When inaccurate informaton is discovered, it will be corrected as promptly as possible.

DISCLOSING INFORMATION TO THIRD PARTIES. The Credit Union will not disclose personal nonpublic informaton to non-affiliated third partes without first providing the consumer a clear and conspicuous notce that accurately reflects the Credit Union’s privacy policies and practces, and providing the consumer a reasonable opportunity to opt out of such disclosure, and the consumer has not opted-out. The Credit Union may share personal nonpublic informaton with its affiliate, if applicable. The Credit Union also may share its experience informaton about the member with credit bureaus. The Credit Union’s reportng to credit bureaus is governed by the Fair Credit Reportng Act, which affords the member the right to make sure that its credit bureau reports are accurate. The requirement for the Credit Union to provide notce and a reasonable opportunity to opt out does not apply if the Credit Union’s disclosure of nonpublic personal informaton is necessary to effect, administer, or enforce a transacton that a consumer requests or authorizes, or in connecton with any of the following:
A. Servicing or processing a financial product or service that a consumer requests or authorizes.
B. Maintaining or servicing the consumer’s account with the Credit Union, or with another entty as part of a private label credit card program or other extension of credit on behalf of such entty.
C. A proposed or actual securitzaton, secondary market sale (including sales of servicing rights) or similar transactons related to a transacton of the consumer.
D. With the writen consent or directon of the consumer, provided the consumer has not revoked the consent or directon.
E. To protect the confidentality or security of the Credit Union’s records pertaining to the consumer, the service or product, or the transacton; to protect against or prevent actual or potental fraud, unauthorized transactons, claims, or other liability; for required insttutonal risk control, or for resolving customer disputes or inquires; to persons holding a legal or beneficial interest relatng to the consumer; or, to persons actng in a fiduciary or representatve capacity on behalf of the consumer.
F. To the extent specifically permited or required under other provisions of law and in accordance with the Right to Financial Privacy Act, to law enforcement agencies, self regulatory organizatons, or for an investgaton on a mater related to public safety.
G. To provide informaton to insurance rate advisory organizatons, guaranty funds or agencies, applicable ratng agencies of the Credit Union, persons assessing the Credit Union’s compliance with industry standards, and the insttuton’s atorneys, accounts, and auditors.
H. To a credit reportng agency in accordance with the Fair Credit Reportng Act.
I. In connecton with a proposed or actual sale, merger, transfer, or exchange of all or a porton of a business or operatng unit if the disclosure of nonpublic personal informaton concerns solely consumers of such business or unit.
J. To comply with Federal, State, or local laws, rules, and other applicable legal requirements, to comply with a properly authorized civil, criminal, or regulatory investgaton or subpoena or summons by Federal, State or local authorites having jurisdicton over the financial insttuton for examinaton, compliance, or other purposes as authorized by law.
K. Such financial records are disclosed (i) in response to an administratve subpoena; (ii) in response to a search warrant; (iii) in response to a judicial subpoena; or (iv) in response to a formal writen request by a proper governmental authority.

RESPONSIBILITY OF SERVICE PROVIDERS. The Credit Union will only approve service providers with established policies of privacy similar to those of the Credit Union. The Credit Union will require contractual agreements from non-affiliated third partes that will include confidentality of member informaton disclosed by the Credit Union and prohibit the service provider from disclosure and reuse of nonpublic personal informaton for any reason other than the intended purpose.

DISCLOSURE OF PRIVACY POLICY. The Credit Union will disclose its privacy policy as required by law, in a form that the members can keep. This disclosure will be in the form of an inital disclosure and will also be provided to members annually if changes are made to the disclosure or if the Credit Union provides an opt-out opton. The Credit Union will provide the required notces in conformance with the model privacy notce contained in the regulaton.
A. Inital Privacy Notce. The Credit Union will deliver a notce describing the Credit Union’s privacy policy to each new member/consumer who establishes a relatonship with the Credit Union. This inital privacy notce will be provided at or before an establishment of a member
relatonship (i.e., before the member/consumer signs the account card or other applicable document). A new privacy notce need not be given for each subsequent account opening, if the privacy notce provided for the one-tme mailing to existng members or the policy at new account opening has not changed from the previously provided privacy notce.
i. Joint Relatonships. When two or more consumers jointly obtain a financial product or service, other than a loan, from the Credit Union, the Credit Union may provide one inital notce to the consumers jointly.
B. Annual Notce. Unless otherwise exempt, the Credit Union will provide a notce of the Credit Union’s privacy policy to all members/consumers at least annually (once during any 12 consecutve months) if the changes are made to their policy or if the Credit Union provides an opt-out opton. The Credit Union need not provide an annual notce to members or consumers who no longer have a relatonship with the Credit Union.
C. Content. As required by law, the inital and annual privacy notces will contain the following informaton:
i. The categories of nonpublic personal informaton that the Credit Union collects;
ii. The categories of nonpublic personal informaton that the Credit Union discloses;
iii. The categories of affiliates and nonaffiliated third partes to whom the Credit Union
discloses nonpublic personal informaton (other than such disclosures allowed by law);
iv. The categories of nonpublic personal informaton about the Credit Union’s former members that is disclosed and the categories of affiliated and nonaffiliated third partes to whom such informaton is disclosed (other than such disclosures allowed by law);
v. If the Credit Union discloses nonpublic personal informaton to a nonaffiliated third party (and no excepton applies to that disclosure), a separate statement of the categories of informaton the Credit Union discloses, and the categories of third partes with whom the Credit Union has contracted;
vi. If applicable, an explanaton of the consumer’s right to opt out of the disclosure of nonpublic personal informaton to nonaffiliated third partes, including the methods by which the consumer may exercise that right at that tme;
vii. Any disclosures made by the Credit Union under the Fair Credit Reportng Act (i.e., notces regarding the ability to opt out of disclosures of informaton among affiliates); and
viii. The Credit Union’s policies and practces with respect to protectng the confidentality and security of nonpublic personal informaton.
D. Privacy Notce May Be Combined With or In Other Documents. The Credit Union’s privacy notce may be combined with other informaton, so long as it is presented in a way that is “clear and conspicuous”; intact so that each consumer can retain its content, and will retain the same
page orientaton, content, format and order as provided in the model notce contained in the regulaton.

MEMBERS’ RIGHT TO “OPT OUT”. Privacy regulatons allow members to “opt out” of having their informaton disclosed to non-affiliated third partes in certain situatons. Before the Credit Union discloses any member informaton to a non-affiliated third party that is not otherwise covered by a disclosure excepton in the regulaton, the Credit Union will properly inform members of their right to “opt out” and to record and honor “opt out” requests. The opt out notce shall include the address and toll-free phone number of the appropriate notficaton system used for processing of notces of opt out and will be presented in a format acceptable to the Natonal Credit Union
Administraton/Federal Trade Commission.
A. Content. As required by law, the opt out notce will state the following informaton:
i. That the Credit Union discloses or reserves the right to disclose nonpublic personal informaton about the consumer to a nonaffiliated third party (including the categories of informaton and the categories of nonaffiliated third partes to whom it is disclosed);
ii. That the consumer has a right to opt out of that disclosure; and
iii. A reasonable means by which the consumer may exercise that opt out right. Examples:
a. Designatng check-off boxes in a prominent positon on the relevant forms with the opt out notce;
b. Including a reply form together with the opt out notce;
c. Providing an electronic means to opt out, such as a form that can be sent via electronic mail or a process at the Credit Union’s website, if the consumer agrees to the electronic delivery of informaton; or
d. Providing a toll-free telephone number that consumers may call to opt out.
iv. How the Credit Union will treat an opt out directon by a joint consumer.
B. Delivery after Inital Notce is Provided. If the Credit Union provides the opt out notce a􀅌er the inital notce is provided, the Credit Union will include a copy of the inital notce in writng or, if the consumer agrees, electronically.
C. Exceptons to Providing an Opt Out Notce. Under the following scenarios, an opt out notce need not be provided to members when nonpublic personal informaton is disclosed to nonaffiliated third partes:
i. Sharing nonpublic personal informaton with a non-affiliated third party in order to carry out a service on the Credit Union’s behalf, and with whom the Credit Union has a writen agreement (i.e., joint marketng agreement) that prohibits further disclosure by the third party;
ii. Disclosure that is necessary to effect, administer or enforce a transacton that a consumer requests or authorizes;
iii. Disclosure with the consent of the consumer (provided it has not been revoked);
iv. Disclosure in order to protect the confidentality or security of the Credit Union’s records pertaining to the consumer, service, product or transacton;
a. To protect against or prevent actual or potental fraud, unauthorized transactons, claims or other liability;
b. For required insttutonal risk control or for resolving consumer disputes or inquiries;
c. Disclosure to persons actng in a fiduciary or representatve capacity on behalf of a consumer;
v. Disclosure in order to provide informaton to insurance rate advisory organizatons, guaranty funds or agencies, agencies that are ratng the Credit Union, persons that are assessing the Credit Union’s compliance with industry standards, and the Credit Union’s atorneys, accountants and auditors;
vi. Disclosure to the extent specifically permited or required under other provisions of law and in accordance with the Right to Financial Privacy Act, to law enforcement agencies, a state insurance authority, self-regulatory organizatons, or for an investgaton on a mater related to public safety;
vii. Disclosure to a consumer reportng agency in accordance with the Fair Credit Reportng Act;
viii. Disclosure in connecton with an actual sale, merger, transfer or exchange of all or a porton of business or operatng unit if the disclosure of nonpublic personal informaton concerns solely consumers of such business or unit; or
ix. To comply with federal, state or local laws, rules and other applicable legal requirements.
D. Joint Relatonships. When two or more consumers jointly obtain a financial product or service, other than a loan, from the Credit Union, the Credit Union may provide only a single opt out notce.
E. Duraton of Opt Out. A consumer’s directon to opt out is effectve untl the consumer revokes it in writng or, if the consumer agrees, electronically.
i. When a member relatonship terminates, the member’s opt out directon contnues to apply to the nonpublic personal informaton that the Credit Union collected during or related to the relatonship. If the individual later establishes a new relatonship with the Credit Union, the opt out directon that applied to the former relatonship does not apply to the new relatonship.

DELIVERY OF PRIVACY AND OPT OUT NOTICES. The Credit Union may reasonably expect that a consumer will receive actual notce of the privacy notce and opt-out right (if applicable) if the Credit Union uses one of the following methods of delivery:
A. Hand-delivery to the consumer, or mailing a printed copy of the notce to the consumer’s last known address;
B. For a consumer who conducts transactons electronically, postng the notce on the electronic site and requiring the consumer to acknowledge receipt of the notce as a necessary step to obtaining a partcular financial product or service; or
C. For an isolated transacton with a consumer (such as an ATM transacton), postng the notce on the ATM screen and requiring the consumer to acknowledge receipt of the notce as a necessary step to obtaining a partcular financial product or service.

REVISED PRIVACY NOTICES. The Credit Union will provide a revised privacy notce (and a new opt out notce, if and when applicable) in the following circumstances:
A. The Credit Union discloses a new category of nonpublic personal informaton to any nonaffiliated third party;
B. The Credit Union discloses nonpublic personal informaton to a new category of non-affiliated third party; or
C. The Credit Union discloses nonpublic personal informaton about a former member to a non-affiliated third party, and that former member has not had the opportunity to exercise an opt out right regarding that disclosure.

CONFIDENTIALITY AND SECURITY SAFEGUARDS. The Credit Union maintains strict policies and security controls to assure that nonpublic personal informaton in the Credit Union’s computer systems and files is protected.
A. Credit Union employees and certain contractors are permited access to nonpublic personal informaton that they may need to perform their jobs and to provide service to the members.
B. Credit Union employees and contractors will have access to such nonpublic personal
informaton only as necessary to conduct a transacton or respond to a member’s inquiries.
C. All Credit Union employees and contractors will be required to respect member privacy through confidentality and informaton security provisions included in the Credit Union’s employee policy manual and service agreements with the contractors.
D. No one except Credit Union employees and authorized contractors will have regular access to the Credit Union computer system and records storage. The Credit Union has established internal security controls, including physical, electronic and procedural safeguards to protect the member nonpublic personal informaton provided to the Credit Union and the informaton the Credit Union collects about the member. The Credit Union will contnue to review its internal security controls to safeguard member nonpublic personal informaton as the Credit Union employs new technology in the future.

PRIVACY OF ELECTRONIC TRANSACTIONS.
A. Encrypton. Electronic interfaces with members (such as Internet transactons) will be encrypted using Secure Socket Layer (SSL) 128-bit encrypton.
B. Account Access. Member account informaton and transactons will be protected by a password that must be used in conjuncton with a username or account number. Members must apply for this capability and be registered with the Credit Union for authentcaton purposes.
C. “Cookies”. The Credit Union website uses “cookies” as part of its website interface. A “cookie” is a small file that is placed on the user’s computer. While it contains no member informaton, it identfies the member’s computer and allows the Credit Union to measure usage of the website and customize the website experience.
i. The Credit Union will disclose whether it collects cookies on its website.
D. Links. The Credit Union will frequently link to other sites as a convenience to our members. The Credit Union will seek to link with other sites that adhere to similar privacy standards. For all third-party links, the Credit Union will disclose the following informaton:
i. The member is leaving the Credit Union’s website;
ii. The member is linking to an alternate website not operated by the Credit Union;
iii. The Credit Union is not responsible for the content of the alternate website;
iv. The Credit Union does not represent either the third party or the member if the two enter into a transacton; and
v. Privacy and security policies may differ from those practced by the Credit Union.
E. Online Privacy of Children’s Informaton. The Credit Union will not collect, use or disclose online informaton received from children under age 13 without prior parental notficaton and consent, which will include an opportunity for the parent to prevent use of informaton and partcipaton in the actvity. Online informaton will only be used to respond directly to the child’s request and will not be used for other purposes without prior parental consent.
i. The Credit Union will not distribute to third partes, other than its affiliate, personally identfiable informaton without prior parental consent.
ii. The Credit Union will not post or otherwise distribute personally identfiable informaton without prior parental consent.
iii. The Credit Union will not entce by the prospect of a special game, prize or other actvity, to divulge more informaton than is needed to partcipate in the actvity.
iv. Personally identfiable informaton that is collected online from their children may be reviewed by a parent or guardian upon writen request. The parent or guardian has the right to have informaton deleted and instruct the Credit Union to cease collectng further informaton from their child.

PRIVACY COMPLIANCE. The Credit Union and all of its affiliates will comply with all applicable laws and regulatons governing the privacy, confidentality, security, and integrity of nonpublic personal informaton including the Consumer Financial Protecton Bureau (CFPB)’s Privacy of Consumer Financial Informaton rule (Regulaton P) and all other applicable state and federal privacy laws and regulatons as amended.

ADMINISTRATION AND AMENDMENTS.
A. Protectng member privacy is an ongoing process and the Credit Union will contnue to evaluate and review the measures taken to safeguard member informaton.
B. The Credit Union will provide training to employees on how to recognize and control risk to nonpublic personal informaton, how to handle nonpublic personal informaton, and how to report unauthorized or fraudulent atempts to gain access to nonpublic personal informaton.
C. The Credit Union will create controls and procedures whereby any new product, service, or
delivery method shall be reviewed and modified to ensure that it conforms to existng Credit Union privacy policies with regards to nonpublic personal informaton.
D. If nonpublic personal informaton is shared with vendors for a business purposes, all contracts and agreements between the vendors and the Credit Union will include a guarantee that the vendor will safeguard such informaton.
E. Because no policy can address every possible contngency and circumstances, Credit Union management shall use its good faith business judgment in administering this privacy policy and expects that all officers, volunteers and employees will use good faith in their actons to protect the privacy of Credit Union members.
F. The Credit Union reserves the right to amend this privacy policy in any respect with disclosure to members as required by law.

ACCESS TO FINANCIAL RECORDS BY FEDERAL GOVERNMENT AUTHORITIES. To obtain a member’s financial records, the Right to Financial Privacy Act requires the federal governmental authority to first obtain:
A. An authorizaton, signed and dated by the member, that:
i. Authorizes such disclosure for a period not to exceed 3 months;
ii. States that the member may revoke such authorizaton at any tme before the financial
records are disclosed;
iii. Identfies the financial records authorized to be disclosed;
iv. Specifies the purposes for which, and the government authority to which, such records
may be disclosed; and
v. States the member’s rights under the Act.
B. An administratve subpoena or summons.
i. It is important to keep dates regarding the subpoena. The Credit Union needs writen notce that all required elements have been compiled by the federal agency prior to mailing required informaton back to the agency.
ii. The Credit Union may release member informaton only if:

The Credit Union has reason to believe that the records sought are related to a legitmate law enforcement inquiry;

The member has been served with a copy of the subpoena on or before the Credit Union is served, and the Credit Union receives a copy of a notce sent to the member specifically describing the nature of the inquiry; and

The Credit Union waits 10 days from the date the member was served (or 14 days if the member was served by mail) to see if notce is received that the member has filed a moton to stop the subpoena.
C. A search warrant.
D. A judicial subpoena.
i. If the member does not challenge the subpoena in court, upon expiraton of 10 days from the date of service by the court (or 14 days if the notce was mailed to the member), the records may be made available to the federal government agency.
ii. It is important to keep dates regarding the subpoena. The Credit Union needs writen notce that all required elements have been compiled by the federal agency prior to mailing required informaton back to the agency.
E. A formal writen request by a government agency (to only be used if no other authority is
available).
i. If the member does not challenge the formal writen request in court, upon expiraton of 10 days from the date of service by the court (or 14 days if the notce was mailed to the member), the records may be made available to the federal government agency.

CERTIFICATION. Upon receipt of a request for financial records by a federal government agency, the Credit Union must assemble the requested records and be prepared to deliver them. The records may not be released untl the Credit Union receives a writen certficaton from the federal government agency that it has complied with the Act.

DELAYED NOTICE. The Credit Union may be required to delay the disclosure to the member that records have been obtained or that a request for records has been made for 90 days or indefinitely if a judge finds that:
A. The investgaton being conducted is with the lawful jurisdicton of the government authority seeking the financial records;
B. There is reason to believe that the records being sought are relevant to a legitmate law enforcement inquiry; and
C. There is reason to believe that such notce will result in:
i. Endangering life or physical safety of any person;
ii. Flight from prosecuton;
iii. Destructon of or tampering with evidence;
iv. Intmidaton of potental witnesses; or
v. Otherwise seriously jeopardizing an investgaton or official proceeding or unduly delaying a trial or ongoing official proceeding.

EXCEPTIONS. The Act’s notficaton and certficaton requirements do not apply to the following types of disclosures to federal government agencies:
A. When the disclosure is pursuant to the filing of a Suspicious Actvity Report when the Credit Union believes that informaton may be relevant to a possible violaton of a statute or regulaton.
B. When the disclosure is accordance with procedures authorized by the Internal Revenue Code.
C. When the request for disclosure is not identfied with a partcular member, which also includes records or informaton that is not identfiable as being derived from the financial records of a partcular member.
D. When the request for disclosure is pursuant to the exercise of supervisory, regulatory or monetary functons with respect to financial insttutons (for example, examinatons).
E. When the request is for disclosure is sought under the Federal Rules of Civil or Criminal Procedure, or comparable rules of other courts in connecton with litgaton to which the government authority and the members are partes.
F. When the request is pursuant to lawful proceeding or investgaton directed at a financial insttuton or legal entty.
G. When the disclosure is incident to perfecton of a security interest, proving a claim in bankruptcy, collectng a debt or processing an applicaton with regard to a government loan, loan guarantee or loan insurance agreement.
H. When it is necessary for the government to use or transfer financial records to process, service or foreclose a loan, or to collect on a debt to the government resultng from a member’s default.
I. When the Credit Union discloses what is necessary in order to properly administer programs related to the withholding of taxes on nonresident aliens, Federal Old-Age Survivors, Disability Insurance Benefits and Railroad Retrement Act Benefits.
J. When the request is pursuant to the authority of the Federal Reserve System, Federal Reserve Bank, Federal Housing Finance Agency, or the Federal Home Loan Banks to extend credit to the Credit Union or others.
K. When the request is necessary to administer certain veteran benefits laws.
L. When the request is pursuant to an administratve subpoena issued by an administratve law judge in an adjudicatory proceeding.
M. When the request is pursuant to legitmate law enforcement inquiries and the informaton sought is the name, address, account number and type of account of any member.
N. When the request is pursuant to a grand jury subpoena. (These MUST be kept confidental.)
O. When records are sought by the General Accountng Office pursuant to an authorized proceeding, investgaton, examinaton or audit directed at a government authority.
P. When the Credit Union or supervisory agency provides any record of any officer, director or employee to the Atorney General, a state law enforcement agency, or the Secretary of the Treasury if there is no reason to believe there were crimes against the Credit Union by the insider.
Q. When the disclosure is required pursuant to federal law or regulaton.

SPECIAL PROCEDURES.
A. Access to Financial Records for Certain Intelligence and Protectve Purposes. Aside from the exceptons above, the Credit Union may provide records to:
i. A government authority authorized to conduct foreign counter- or foreign positve intelligence actvites;
ii. The Secret Service for the purpose of conductng its protectve functons;
iii. A government authority to conduct investgatons of, or intelligence or counterintelligence analyses related to, internatonal terrorism for the purpose of conductng such investgatons or analyses; or
iv. The Federal Bureau of Investgaton (FBI) when the Director of the FBI (or the Director’s designee) certfies in writng to the Credit Union that such records are sought for foreign counter-intelligence purposes to protect against internatonal terrorism or clandestne intelligence actvites, provided that such an investgaton of a U.S. person is not conducted solely upon the basis of actvites protected by the first amendment to the
U.S. Consttuton.
v. In these cases, the government authority must submit a certficate to the Credit Union signed by a supervisory official of a rank designated by the head of the government authority.
vi. The Credit Union may not disclose to anyone that a government authority described above has sought or obtained access to a member’ financial records.
B. Emergency Access to Financial Records. The Credit Union may release informaton to a government authority if the government authority determines that delay in obtaining access to such records would create imminent danger of:
i. Physical injury to any person;
ii. Serious property damage; or
iii. Flight to avoid prosecuton.
iv. In these cases, the government authority must submit a certficate to the Credit Union signed by a supervisory official of a rank designated by the head of the government authority.

COST REIMBURSEMENT. The government will reimburse the Credit Union for the reasonable cost directly incurred in searching for, reproducing, or transportng books, papers, records or other data required or requested to be produced