Compliance Blog

Last week, NCUA issued two legal opinion letters. 

First, Legal Opinion Letter 08-0447 (which you can access here) clarifies the 95% condition for credit unions with allotted space in federal credit unions. In NCUA's words:

Under the Federal Credit Union Act, a federal agency may allot building space to a credit union at no charge for rent or services if “at least 95 percent of the membership of the credit union to be served by the allotment of space” are, or were at the time of admission to membership, federal employees or their family members. 12 U.S.C. §1770. This language was enacted in 1993 and amended previous language requiring at least 95 percent of a credit union’s membership be composed of federal employees and their family members. National Defense Authorization Act for Fiscal year 1994, Pub. L. No. 103-160, §2854 (1993) (codified as amended at 12 U.S.C. §1770). The 95% requirement applies to those who would be served by the allotment of space..

For credit unions with offices in federal buildings, this is a must read.

NCUA also issued Legal Opinion Letter 08-0543 (which you can access here), which clarifies whether a credit union can use the names of its sponsor's subsidiaries to name various branch offices.  In NCUA's words:

You have asked whether a federal credit union (FCU) can use the names of its sponsor's subsidiaries to name its branch offices. Yes, FCUs can operate branch offices under a different name than the name of the insured credit union if the FCU takes reasonable steps to ensure members are fully apprised of the use of different names.

***

NAFCU's NAFCU Update (June 16, 2008) is available here. (Members only.)  This weekly newsletter provides a nice overview of regulatory and legislative issues, not to mention other important news for NAFCU and credit unions.