Compliance Blog

Sep 08, 2008
Categories: Board and Governance

Lock Box Accounting Services OK

Last week (NCUA was busy) NCUA issued a legal opinion letter to clarify that credit unions can offer "lock box accounting services" pursuant to NCUA's incidental powers regulation. You can access the opinion letter here.  In NCUA's words...

In a letter to this office, you stated that your FCU proposes to collect monthly rental payments on behalf of a housing cooperative and apply those payments to the cooperative’s accounts. Also under your proposal, your FCU would pay, from the cooperative’s accounts, certain monthly bills and reconcile the account ledger to the monthly statements.

NCUA defines operational programs as programs that an FCU establishes to deliver products and services to members that enhance member service and promote safe and sound operation. 12 C.F.R. §721.3(j). These programs include pre-authorized member transactions and loan collection services. Id. Accordingly, the services you have in mind on behalf of your member are permissible.

So there you have it.  Here's a link to the incidental powers regulation itself.