Compliance Blog

Yesterday, NCUA released two legal opinion letters.

• NCUA released NCUA Legal Opinion Letter 09-0108 (January 26, 2009) to clarify that the Freedom of Information Act (FOIA) does not apply to federal credit unions.  That's nothing new.  But here are a few thoughts.  While members cannot FOIA federal credit unions, they can make formal requests for information pursuant to 12 C.F.R. Part 701.3.  Understand that process, as you have a short timeline to respond.  Also, access NCUA's FOIA page here. 

• NCUA also released NCUA Legal Opinion Letter 08-1024 (January 30, 2009).  This one deals with conflict of interest provisions.  NCUA stated the following:

You have asked if the conflict of interest provision in the National Credit Union Administration’s (NCUA’s) general lending regulation would preclude a credit union from selling loans to a bank in which one of the credit union’s directors owns stock. 12 C.F.R. 701.21(c)(8). We conclude the conflict of interest provisions prohibiting credit union officials from receiving any compensation in connection with making loans does not apply when a credit union sells loans it previously made but, nevertheless, we recommend that, in the circumstances you described, an interested director should recuse himself from deliberating or voting on the transaction.

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After putting together the second bouncy seat yesterday, I decided to get some exercise . (For those who don't know what a bouncy seat is, it seems to be a plastic, colorful child containment system that bounces.  I guess "bouncy seat" sounds nicer than my description.)  My wife suggested that I work through this short yoga booklet that she uses.   This is how it progressed.

Cocky Compliance Guy: This is pretty simple.
Loving Wife:  Just wait.

10 minutes later...

Compliance Guy:  Umm.  This one is pretty hard. 
Laughing, Loving Wife:  Just wait.

Next morning.

Sore Compliance Guy: (Grunts as he gets out of bed.)
I Told You So Wife:  (Giggles.)