Regulatory Update 3/15/16

Letter to NCUA regarding CUSO Registry Acknowledgement: Yesterday, NACUSO informed you of a change we negotiated with our General Counsel (Messick & Lauer) with the NCUA regarding the CUSO Registry Acknowledgment each CUSO is required to agree to when submitting their CUSO registration in the NCUA’s CUSO Registry system.  As we pointed out in our Regulatory Alert yesterday, the acknowledgment required CUSOs to agree to be bound by statutes that only apply to credit unions and which imposed penalties that are not applicable to CUSOs.

As we pointed out in our Regulatory Alert, if you completed your CUSO registration prior to March 11, 2016 when the NCUA changed the acknowledgment in the CUSO Registry, we recommend sending some form of this letter to the NCUA.  This letter clarifies that you are not subjecting your CUSO to statutes and penalties that do not apply to the CUSO, and that you in fact supplied this information to the NCUA pursuant to the contractual obligation between the CUSO and its credit union investors.  We recommend you personalize this draft letter and send to the NCUA prior to March 31, 2016 if you completed your registration in the CUSO Registry prior to the March 11, 2016 change in the acknowledgment we negotiated.

If you are intending to send this letter by email, please use the following email address: cusoregistry@ncua.gov.  This will help NCUA to keep these letters consolidated in the correct area.  Thank you.