Interpretive Letters List
Interpretive letters, formerly known as opinions, clarify RCWs and WACs related to state-chartered Credit Unions.
2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2005 | 2004 | 2003 |
2002 | 2001 | 2000 | 1999 | 1998 | 1997 | 1996 | 1995
2013 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-13-01
|
Use of the Term "Audit Committee" in Credit Union Bylaws
|
03/07/13
|
|
I-13-02
|
State Credit Union Investments in Employee Benefit Trusts
|
02/28/13
|
|
I-13-03
|
Credit Union Owned Life Insurance
|
04/24/13
|
2012 Interpretive Letters
|
| None |
2011 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-11-01
|
Whether a director emeritus is eligible for expense reimbursement for travel or training expenses, or qualifies for insurance benefits
|
01/24/11
|
|
I-11-02
|
May an individual be re-instated as a member under the “once a member, always a member” principle
|
04/13/11
|
|
I-11-03
|
Definition of Vice President
|
06/10/11
|
|
I-11-04
|
Board Member Life Insurance
|
10/28/11
|
2010 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-10-01
|
Contemporaneous use of official credit union name and assumed trade name
|
02/24/10
|
|
I-10-02
|
Summary of 2010 Bill (EHB 2830)
|
04/12/10
|
|
I-10-03
|
Investment in Real Estate
|
05/14/10
|
|
I-10-04
|
Use of a CUSO to Take Assignment of a Delinquent Mortgage Loan and Foreclose, Hold and Dispose of Collateral with Environmental Risks
|
08/09/10
|
|
I-10-05
|
NCUA Regulation Flex in 12 C.F.R. 742.4 and personal guarantees for MBLs
|
12/07/10
|
2009 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-09-01
|
RCW 31.12.365 (2) permitting reimbursement for reasonable expenses for directors and supervisory committee members (official volunteers)
|
02/11/09
|
|
I-09-02
|
Pledge of Credit Union assets |
09/04/09
|
|
I-09-03
|
Clarification of “Master Business License” and Related Exemption Issues for Credit Unions
|
09/08/09
|
|
I-09-04
|
The Extent to Which Credit Unions Can Accept Government Sub-grant Funds
|
12/23/09
|
2008 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-08-01
|
Credit Union "associate" board members
|
01/31/08
|
|
I-08-02r
|
SUSPENDED
|
01/31/08
|
|
I-08-03
|
Clarity Of Consumer Disclosure On Interest Vs. Dividend Payment
|
04/09/08
|
|
I-08-04rr
|
Board Absences
|
09/29/08
|
|
I-08-05r
|
Cancelled and Superseded by Bulletin B-11-05 (pdf)
|
10/03/08
|
2007 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-07-01
|
Establishing no-interest/dividend accounts for members lacking a taxpayer identification number
|
01/08/07
|
|
I-07-02
|
Clarifying what constitutes a MBL construction loan under Chapter 208-460 WAC
|
01/30/07
|
|
I-07-03
|
Use of the word Credit Union in name
|
07/19/07
|
|
I-07-04
|
Offers to make dividend payments during merger situations
|
11/14/07
|
|
I-07-05
|
Conditions of approval for receipt of Visa, Inc. “restructuring” stock
|
11/21/07
|
|
I-07-06
|
Conditions of approval for ownership of MasterCard Class A shares
|
11/29/07
|
2005 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-05-01
|
Board member proxy
|
03/14/05
|
|
I-05-02
|
A credit union may grant loans to its employees at more favorable terms than granted to its members, except employees who are also member of the credit committee (Replaces O-96-14)
|
03/16/05
|
|
I-05-03
|
Credit Unions acting as insurance agents or brokers
|
04/06/05
|
|
I-05-04
|
How and when is a loan counted as a member business loan for calculating per-member and total credit union limit on member business loans?
|
05/27/05
|
|
I-05-05
|
Conflict of interest by candidates for board of directors or supervisory committee positions
|
04/27/05
|
|
I-05-06
|
Credit union payday lending
|
06/09/05
|
|
I-05-07
|
CUSO payday lending
|
06/10/05
|
|
I-05-08
|
Use of the name “credit union” in a URL by a non-credit union
|
07/13/05
|
|
I-05-09
|
DCU authority over a CUSO subsidiary
|
09/13/05
|
|
I-05-10
|
Gifts of minimal value (RCW 31.12.365)
|
12/01/05
|
|
I-05-11
|
Sallie Mae investments
|
12/14/05
|
|
I-05-12
|
Payday lending and refunding application fee deposits
|
12/20/05
|
[Top]
2004 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
I-04-01
|
Member Petition for Special Meeting
|
01/22/04
|
|
I-04-02
|
Credit Union serve as Treasury tax & loan depositories
|
04/30/04
|
|
I-04-03
|
Effect of Conversion from Federal Chartered Credit Union to Washington State Chartered Credit Union
|
06/02/04
|
|
I-04-04
|
Credit unions are authorized to act as trustee or custodian for Health Savings Accounts
|
08/31/04
|
|
I-04-05
|
Can board of directors meet in an executive session and exclude the supervisory committee members?
|
11/29/04
|
[Top]
2003 Interpretive Letters
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|
Number
|
Subject
|
Date
|
|
O-03-01
|
A Washington State Chartered Credit Union May Apply for Approval to Invest in the Business Development Corporation of Eastern Washington, an Industrial Development Corporation.
|
12/30/03
|
[Top]
2002 Interpretive Letters
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|
Number
|
Subject
|
Date
|
|
O-02-01
|
State Credit Unions May Close for Four Consecutive Days After Appropriate Mitigation of Risks
|
01/17/02
|
|
O-02-02
|
A Director May Not Hold More Than One Board Officer Position, Except For Board Treasurer And Secretary
|
04/08/02
|
|
O-02-03
|
Credit Unions Possess Authority To Enter Into Arrangements with Third Parties To Sell Investment and Insurance Products To Members, Subject To Compliance With Applicable Regulatory Pronouncements
|
04/08/02
|
|
O-02-04
|
New Field of Membership (FOM) Rules Effective March 8, 2002
|
04/30/02
|
|
O-02-05
|
Whether Washington State Chartered Credit Unions Can Sell and Finance Debt Cancellation Contracts
|
06/04/02
|
[Top]
2001 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-01-1
|
State Credit Unions May Issue Shares to and Receive Deposits from Members in the Form of Revocable Living Trust Accounts
|
01/16/01
|
|
O-01-2
|
A State Credit Union May Accept Federal Public Funds, But May not Accept State Public Funds
|
02/13/01
|
|
O-01-3
|
Summary of Major Differences Between Washington’s MBL Rule (As Approved by NCUA Board) and NCUA’s MBL Rule
|
03/22/01
|
|
O-01-4
|
Credit Unions May Use Electronic Voting Methods To Elect Directors and Supervisory Committee Members, As Permitted By Their Bylaws
|
05/24/01
|
|
O-01-5
|
Bond Coverage Which Meets Minimums Established in NCUA Rules Is Generally Adequate Under Washington State Credit Union Act
|
06/04/01
|
|
O-01-6
|
#1 Non-US Citizens In A Credit Union’s Field of Membership May Join The Credit Union #2 Credit Union CUSOs May Serve Non-Member IRnet Customers, Subject to RCW 31.12.436(8)
|
08/03/01
|
|
O-01-7
|
Summary of HB 1366 (Chapter 83, Laws of 2001), Effective July 22, 2001
|
09/19/01
|
|
O-01-8
|
Credit Unions Possess Incidental Powers through Two Sources-1. The State Parity Provision (RCW 31.12.404); and 2. The State Incidental Powers Provision (RCW 31.12.402(23))
|
11/02/01
|
[Top]
2000 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-00-1
|
"Spouses" as Used in RCW 31.12.365(2) includes Spousal Equivalents such as Domestic Partner
|
03/31/00
|
|
O-00-2
|
State Credit Unions Can Convert or Merge Into State Mutual Savings
|
03/31/00
|
|
O-00-3
|
Credit Unions May Accept Deposits from Nonmember Credit Unions
|
04/14/00
|
|
O-00-4
|
Interim Director Appointed To Fill A New Board Seat May Serve Only Until The Next Annual Meeting Of Members
|
11/24/00
|
[Top]
1999 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-99-1
|
Can Washington state chartered credit union (WSCCU) provide health, accident, and related types of personal insurance (insurance) to its board members?
|
03/16/99
|
|
O-99-2
|
Approval of CUMIS Corporate Credit Union Bond 150
|
10/04/99
|
|
O-99-3
|
"Once a member, always a member"; Continuing Eligibility of a Member's Family
|
11/30/99
|
|
O-99-4
|
Family Members Of Primary Member May Join Credit Union Even Though Primary Member Ceases To Be Part Of FOM Group
|
11/30/99
|
[Top]
1998 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-98-4
|
Summary of new 1997 Washington State Credit Union Act, Chapter 31.12 RCW, effective January 1, 1998
|
01/01/98
|
|
O-98-1
|
Canceled
|
|
|
O-98-2
|
Requirement for submission of Form FI 6002, 1997 Economic Census, to U.S. Department of Commerce
|
03/27/98
|
|
O-98-3
|
Investment in real property primarily for own use (RCW 31.12.438)
|
04/01/98
|
|
O-98-5
|
Signature guarantee program
|
04/20/98
|
|
O-98-7
|
Disclosure of records to state law enforcement agencies
|
04/23/98
|
|
O-98-6
|
Approval of Progressive Financial Institutions Bond
|
06/24/98
|
|
O-98-8
|
Control of non-profit charitable organization
|
07/09/98
|
|
O-98-9
|
Taking former employees of occupational group as members
|
08/14/98
|
|
O-98-10
|
Effective date of credit union mergers
|
08/14/98
|
|
O-98-11
|
Canceled
|
|
|
O-98-12
|
Definition of "voluntary committee"
|
12/30/98
|
[Top]
1997 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-97-1
|
Cancelled
|
01/07/97
|
|
O-97-5
|
Investment in Federal Home Loan Bank bonds
|
01/30/97
|
|
O-97-2
|
Incidental powers of credit unions with regard to charitable or community contributions
|
02/21/97
|
|
O-97-3
|
Federal parity for state credit unions; NCUA Part 741; supervisory committees and member business loans
|
03/11/97
|
|
O-97-4
|
Authority of state chartered credit union to conduct business on overseas military installations
|
03/24/97
|
|
O-97-6
|
Gifts for retiring directors and supervisory committee members
|
04/11/97
|
|
O-97-7
|
Political contributions
|
04/14/97
|
|
O-97-8
|
Canceled
|
|
|
O-97-9
|
Maintenance of WCUSGA reserves after a merger into a NCUSIF insured credit union
|
05/27/97
|
|
O-97-12
|
Disqualification of director for absence
|
06/04/97
|
|
O-97-10
|
Maintenance of WCUSGA reserves after conversion to NCUSIF
|
06/17/97
|
|
O-97-11
|
Canceled
|
|
|
O-97-13
|
Voting rights of Board Chair
|
07/23/97
|
|
O-97-14
|
Board charge-off of losses
|
08/11/97
|
|
O-97-15
|
Credit Union Service Organization (CUSO) investment-Changes in ownership and purpose
|
08/12/97
|
|
O-97-16
|
Transfer of WCUSGA contingency reserve as of December 31, 1998
|
09/05/97
|
|
O-97-17
|
Effective date of merger of state credit unions or merger of federal into state credit union
|
09/10/97
|
[Top]
1996 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-96-1
|
Response to objections to community FOM application
|
04/11/96
|
|
O-96-2
|
Requirements for out-of-state credit union to do business in Washington
|
04/16/96
|
|
O-96-3
|
Provisions applicable to loans to directors, officers, and employees
|
05/03/96
|
|
O-96-4
|
Exemption from payment of state business and occupation taxes
|
05/08/96
|
|
O-96-5
|
FOM issues: family members and SOGs
|
05/09/96
|
|
O-96-6
|
Division does not protect servicemarks
|
05/13/96
|
|
O-96-7
|
Reimbursement for director’s expense for substitute teacher
|
06/06/96
|
|
O-96-8
|
Incentive pay for share and deposit accounts
|
06/19/96
|
|
O-96-9
|
Imaging of documents
|
08/22/96
|
|
O-96-10
|
Application of Chapter 208-440 WAC to credit union programs
|
08/26/96
|
|
O-96-11
|
Authority to serve as tax and loan depository for U.S. Treasury
|
09/06/96
|
|
O-96-12
|
Using SOG procedure to add small occupational groups within 25 mile radius across state lines
|
09/20/96
|
|
O-96-13
|
Removal of streamlined senior groups from FOM
|
09/23/96
|
|
O-96-14
|
Loans to credit union employees and officials (Updated-See I-05-02)
|
10/08/96
|
|
O-96-15
|
Sublease of space to travel agent under Chapter 208-440 WAC
|
10/29/96
|
|
O-96-16
|
Response to objections to community FOM application
|
11/25/96
|
|
O-96-17
|
Continued validity of Chapter 208-440 WAC (participation in commercial business activities)
|
12/03/96
|
|
O-96-18
|
Canceled
|
|
|
O-96-19
|
Telephone conferencing for board meetings
|
12/10/96
|
|
O-96-21
|
Payment of membership fee or purchase of shares to join a credit union
|
12/17/96
|
|
O-96-20
|
Counting mail ballots to reach quorum at membership meeting
|
12/31/96
|
[Top]
1995 Interpretive Letters
|
|
Number
|
Subject
|
Date
|
|
O-95-1
|
Direct marketing in FOM community (formally 95-A)
|
05/18/95
|
|
O-95-2
|
Interpretation of Chapter 419-64 WAC
|
09/28/95
|
|
O-95-5
|
Response to comment letters on Columbia conversion
|
09/28/95
|
|
O-95-3
|
Use of the term "credit union" in the name of your company
|
11/01/95
|
|
O-95-4
|
The Exchange/Electronic Data Systems Corporation- Proposed Joint Venture
|
11/22/95
|
[Top]
