Ms. Shewan M. Holmes
Manager, IEC Federal Credit Union
P.O. Box 3787
Springfield, IL 62708
Re: Supervisory Committee Members (Your November 22, 1996, Letter)
Dear Ms. Holmes:
You have written seeking a legal opinion on the permissibility of members of the supervisory committee also serving as loan officers. Specifically, you ask if this is a violation of the Federal Credit Union Act (Act). Although not a violation of the Act, the practice you have described is a violation of sound internal controls and should be discontinued. I have enclosed for your review the provision in NCUA's Accounting Manual which discusses the importance of sound internal controls as well as a chart showing the positions in a federal credit union and the persons who are prohibited from holding them.
Sincerely,
Michael J. McKenna
Acting Associate General Counsel
GC/MFR:bhs
SSIC 3000
96-1136
Enclosure
cc: Nicholas Veghts, Region IV Director