March 19, 2024
VIA FEDERAL EXPRESS OVERNIGHT MAIL
Sarah C. Conley
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Re: Notice of Prohibition
Dear Ms. Conley:
The National Credit Union Administration (“NCUA”) is the federal regulator for federally chartered or insured credit unions. The NCUA is aware that on or about March 28, 2022, you were convicted in Onondaga County Court on the offense of Grand Larceny in the Second Degree, P.L. §155.40(1). State of New York v. Sarah C. Conley, Docket Number: SCI-70992-22/001. Your conviction was in connection with illegal activities at Summit Federal Credit Union, Rochester, New York. You were subsequently sentenced to five years of probation and ordered to pay restitution.
This letter is to notify you that as a result of your conviction you are subject to the prohibitions set forth in 12 U.S.C. §§ 1785(d) and 1829. As such, without the prior written consent of the NCUA or Federal Deposit Insurance Corporation, these sections prohibit you by operation of law from becoming an “institution-affiliated party” of any insured depository institution (as defined in 12 U.S.C §§ 1786(r) or 1813(u)), or otherwise participating, directly or indirectly, in the conduct of the affairs of any insured depository institution, and owning or controlling, directly or indirectly, any insured depository institution.
Sections 1785(d) and 1829 impose criminal penalties of up to five years imprisonment and a fine of up to $1,000,000 for each day of violation. Should a knowing violation of these sections occur, both you and the institution would be subject to the penalties provided by the statute. These statutes do not prohibit you from being a member of a credit union, or customer of a bank or savings association.
Sections 1785(d) and 1829 provide exceptions and exemptions for certain offenses, however, the offense referenced above does not currently meet the exception or exemption criteria. If you believe that your conviction is not covered by sections 1785(d) or 1829, please contact this office immediately at ogcmail@ncua.gov or 703.518.6540.
Be advised that a copy of this letter will be available on the NCUA’s public website and will remain on the website until the criminal offense referenced above is no longer covered by the statutes.
Sincerely,
/s/
Frank S. Kressman
General Counsel