Compliance Question of the Week
February 14, 2012
February 14, 2012
What does “Immediate Family Member” mean in our field of membership (FOM)?
There is a big difference between state-chartered and federally-chartered credit unions when it comes to the definition of a family member.
For federally-chartered credit unions (FCUs), the National Credit Union Administration (NCUA) defines immediate family member(s) as a spouse, child, sibling, parent, grandparent, or grandchild of the primary potential member. An FCU can adopt a “board policy” to create a family policy that is more restrictive than the NCUA definitions.
For state-chartered credit unions in Washington, the Washington Administrative Code of credit unions FOM states “Family members (as determined by the credit union) of any of the above-described natural persons.” In effect, the state-chartered credit unions are free to determine their own definition of “family member.” This could include domestic partners or be restricted to just spouse and children.
For an Oregon state-chartered credit union, the Oregon Administrative rules state
(11) “Members of the immediate family” means:
- All of the following relatives of the member: grandparents, parents, spouse, children, stepchildren, grandchildren, brothers, sisters, half-brothers, half-sisters, aunts and uncles;
- The domestic partner of a member provided the domestic partner and the primary member attest that the following conditions apply:
- They share the same regular and permanent address;
- Have a close personal relationship; and
- Have agreed to be jointly responsible for basic living expenses and each other’s common welfare; and
Questions? Contact the Compliance Hotline: 1.800.546.4465, firstname.lastname@example.org.