Interpretive Letters List
Interpretive letters, formerly known as opinions, clarify RCWs and WACs related to state-chartered Credit Unions.
2008 | 2007 | 2005 | 2004 | 2003 | 2002 | 2001 | 2000 | 1999 | 1998 | 1997 | 1996 | 1995
2008 Interpretive Letters |
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| 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 |
2007 Interpretive Letters |
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| 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 |
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| 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 |
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2004 Interpretive Letters |
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| 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 |
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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 |
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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 |
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2001 Interpretive Letters |
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| 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 |
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2000 Interpretive Letters |
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| 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 |
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1999 Interpretive Letters |
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| 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 |
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1998 Interpretive Letters |
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| 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 |
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1997 Interpretive Letters |
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| Number | Subject | Date |
| O-97-1 | Limitation of director liability; indemnification of directors, supervisory committee members, and employees | 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 |
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1996 Interpretive Letters |
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| 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 |
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1995 Interpretive Letters |
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| 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 |
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