NCUA Publishes Approved Corporate CUSO Activities
March 30, 2011 NCUA’s Office of Corporate Credit Unions (OCCU) has begun publishing approved activities for corporate credit union CUSOs on a new dedicated page on the NCUA web site. To date, the approved activities include:
- Business consulting services
- Human resources services
- Marketing and research services
- Payroll services
- Training services
- Audit and compliance consulting services
- Product development services
In addition to listing these approved corporate CUSO activities (CCAs), the OCCU web page also provides information on reporting requirements. All corporate CUSOs engaged in approved CCAs must provide OCCU quarterly financial statements and performance reports. They must also annually provide OCCU with the Annual Report to Owners; audited financial statements; lists of current owners with percentages of ownership; and a list and description of all products and services offered.
In January of this year, OCCU issued Letter to Corporate Credit Unions (LTCCU) 2011-01 to provide guidance for obtaining NCUA approval of corporate credit union CUSO activities pursuant to new final §704.11(e). Beginning April 18, 2011, corporate CUSOs must limit their activities to those services pre approved in §704.11(e) or approved by NCUA and published on the agency’s website. The pre approved activities include brokerage and investment services. Once NCUA publishes an additional approved activity on its website, any corporate CUSO may engage in that activities within any parameters established with publication of the approval.
LTCCU 2011-01 instructed corporate CUSOs currently engaged in non-pre approved activities to apply to NCUA for approval by March 31, 2011. After April 18, 2011, corporate CUSOs engaged in non-approved activities must either cease those activities, or any corporate credit union owners/investors must extricate themselves from the CUSO by October 20, 2011.
A NASCUS summary of the guidance may be read here.