Permissibility of a Federal Credit Union (FCU) Providing Locked Box Accounting Services to Members

Dear Ms. Cousminer:

You have asked if an FCU can provide locked box accounting services to its members under the
operational programs category of NCUA’s incidental powers regulation. Yes, it is within an FCU’s
incidental powers to offer these types of services to its members.

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.

 

If you have any further questions please contact Staff Attorney Justin Anderson or me.