Washington State Department of Financial Institutions

Interpretive Letters List

Interpretive letters, formerly known as opinions, clarify RCWs and WACs related to state-chartered Credit Unions.

Director's Interpretive Statements
See also: Director's Interpretive Statements

By Year:

2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2005 | 2004 | 2003 | 2002 | 2001 | 2000 | 1999 | 1998 | 1997 | 1996 | 1995

2014 Interpretive Letters

Number Subject Date
I-14-01 SBA Program 02/11/14
I-14-02 When is a Board Member Disqualified Due to Unexcused Absences 05/14/14
I-14-03 Referring to a Board of Directors as a “Board of Trustees” 05/20/14
I-14-04 Charitable Donation Accounts 07/15/14

2013 Interpretive Letters

Number Subject Date
I-13-01 Use of the Term "Audit Committee" in Credit Union Bylaws 03/07/13
I-13-02 State Credit Union Investments in Employee Benefit Trusts 02/28/13
I-13-03 This interpretive letter has been revised.

See I-13-04
I-13-04 Credit Union Owned Life Insurance 07/15/13

2012 Interpretive Letters


2011 Interpretive Letters

Number Subject Date
I-11-01 Whether a director emeritus is eligible for expense reimbursement for travel or training expenses, or qualifies for insurance benefits 01/24/11
I-11-02 May an individual be re-instated as a member under the “once a member, always a member” principle 04/13/11
I-11-03 Definition of Vice President 06/10/11
I-11-04 Board Member Life Insurance 10/28/11

2010 Interpretive Letters

Number Subject Date
I-10-01 Contemporaneous use of official credit union name and assumed trade name 02/24/10
I-10-02 Summary of 2010 Bill (EHB 2830) 04/12/10
I-10-03 Investment in Real Estate 05/14/10
I-10-04 Use of a CUSO to Take Assignment of a Delinquent Mortgage Loan and Foreclose, Hold and Dispose of Collateral with Environmental Risks 08/09/10
I-10-05 NCUA Regulation Flex in 12 C.F.R. 742.4 and personal guarantees for MBLs 12/07/10

2009 Interpretive Letters

Number Subject Date
I-09-01 RCW 31.12.365 (2) permitting reimbursement for reasonable expenses for directors and supervisory committee members (official volunteers) 02/11/09
I-09-02 Pledge of Credit Union assets 09/04/09
I-09-03 Clarification of “Master Business License” and Related Exemption Issues for Credit Unions 09/08/09
I-09-04 The Extent to Which Credit Unions Can Accept Government Sub-grant Funds 12/23/09

2008 Interpretive Letters

Number Subject Date
I-08-01 Credit Union "associate" board members 01/31/08
I-08-02r SUSPENDED 01/31/08
I-08-03 Clarity Of Consumer Disclosure On Interest Vs. Dividend Payment 04/09/08
I-08-04rr Board Absences 09/29/08
I-08-05r Cancelled and Superseded by Bulletin B-11-05 (pdf) 10/03/08

2007 Interpretive Letters

Number Subject Date
I-07-01 Establishing no-interest/dividend accounts for members lacking a taxpayer identification number 01/08/07
I-07-02 Clarifying what constitutes a MBL construction loan under Chapter 208-460 WAC 01/30/07
I-07-03 Use of the word Credit Union in name 07/19/07
I-07-04 Offers to make dividend payments during merger situations 11/14/07
I-07-05 Conditions of approval for receipt of Visa, Inc. “restructuring” stock 11/21/07
I-07-06 Conditions of approval for ownership of MasterCard Class A shares 11/29/07

2005 Interpretive Letters

Number Subject Date
I-05-01 Board member proxy 03/14/05
I-05-02 A credit union may grant loans to its employees at more favorable terms than granted to its members, except employees who are also member of the credit committee (Replaces O-96-14) 03/16/05
I-05-03 Credit Unions acting as insurance agents or brokers 04/06/05
I-05-04 How and when is a loan counted as a member business loan for calculating per-member and total credit union limit on member business loans? 05/27/05
I-05-05 Conflict of interest by candidates for board of directors or supervisory committee positions 04/27/05
I-05-06 Credit union payday lending 06/09/05
I-05-07 CUSO payday lending 06/10/05
I-05-08 Use of the name “credit union” in a URL by a non-credit union 07/13/05
I-05-09 DCU authority over a CUSO subsidiary 09/13/05
I-05-10 Gifts of minimal value (RCW 31.12.365) 12/01/05
I-05-11 Sallie Mae investments 12/14/05
I-05-12 Payday lending and refunding application fee deposits 12/20/05


2004 Interpretive Letters

Number Subject Date
I-04-01 Member Petition for Special Meeting 01/22/04
I-04-02 Credit Union serve as Treasury tax & loan depositories 04/30/04
I-04-03 Effect of Conversion from Federal Chartered Credit Union to Washington State Chartered Credit Union 06/02/04
I-04-04 Credit unions are authorized to act as trustee or custodian for Health Savings Accounts 08/31/04
I-04-05 Can board of directors meet in an executive session and exclude the supervisory committee members? 11/29/04


2003 Interpretive Letters

Number Subject Date
O-03-01 A Washington State Chartered Credit Union May Apply for Approval to Invest in the Business Development Corporation of Eastern Washington, an Industrial Development Corporation.  12/30/03


2002 Interpretive Letters

Number Subject Date
O-02-01 State Credit Unions May Close for Four Consecutive Days After Appropriate Mitigation of Risks 01/17/02
O-02-02 A Director May Not Hold More Than One Board Officer Position, Except For Board Treasurer And Secretary 04/08/02
O-02-03 Credit Unions Possess Authority To Enter Into Arrangements with Third Parties To Sell Investment and Insurance Products To Members, Subject To Compliance With Applicable Regulatory Pronouncements 04/08/02
O-02-04 New Field of Membership (FOM) Rules Effective March 8, 2002 04/30/02
O-02-05 Whether Washington State Chartered Credit Unions Can Sell and Finance Debt Cancellation Contracts 06/04/02


2001 Interpretive Letters

Number Subject Date
O-01-1 State Credit Unions May Issue Shares to and Receive Deposits from Members in the Form of Revocable Living Trust Accounts 01/16/01
O-01-2 A State Credit Union May Accept Federal Public Funds, But May not Accept State Public Funds 02/13/01
O-01-3 Summary of Major Differences Between Washington’s MBL Rule (As Approved by NCUA Board) and NCUA’s MBL Rule 03/22/01
O-01-4 Credit Unions May Use Electronic Voting Methods To Elect Directors and Supervisory Committee Members, As Permitted By Their Bylaws 05/24/01
O-01-5 Bond Coverage Which Meets Minimums Established in NCUA Rules Is Generally Adequate Under Washington State Credit Union Act 06/04/01
O-01-6 #1 Non-US Citizens In A Credit Union’s Field of Membership May Join The Credit Union #2 Credit Union CUSOs May Serve Non-Member IRnet Customers, Subject to RCW 31.12.436(8) 08/03/01
O-01-7 Summary of HB 1366 (Chapter 83, Laws of 2001), Effective July 22, 2001 09/19/01
O-01-8 Credit Unions Possess Incidental Powers through Two Sources-1. The State Parity Provision (RCW 31.12.404); and 2. The State Incidental Powers Provision (RCW 31.12.402(23)) 11/02/01


2000 Interpretive Letters

Number Subject Date
O-00-1 "Spouses" as Used in RCW 31.12.365(2) includes Spousal Equivalents such as Domestic Partner 03/31/00
O-00-2 State Credit Unions Can Convert or Merge Into State Mutual Savings 03/31/00
O-00-3 Credit Unions May Accept Deposits from Nonmember Credit Unions 04/14/00
O-00-4 Interim Director Appointed To Fill A New Board Seat May Serve Only Until The Next Annual Meeting Of Members 11/24/00


1999 Interpretive Letters

Number Subject Date
O-99-1 Can Washington state chartered credit union (WSCCU)  provide health, accident, and related types of personal insurance (insurance) to its board members? 03/16/99
O-99-2 Approval of CUMIS Corporate Credit Union Bond 150 10/04/99
O-99-3 "Once a member, always a member"; Continuing Eligibility of a Member's Family 11/30/99
O-99-4 Family Members Of Primary Member May Join Credit Union Even Though Primary Member Ceases To Be Part Of FOM Group 11/30/99


1998 Interpretive Letters

Number Subject Date
O-98-4 Summary of new 1997 Washington State Credit Union Act, Chapter 31.12 RCW, effective January 1, 1998 01/01/98
O-98-1 Canceled
O-98-2 Requirement for submission of Form FI 6002, 1997 Economic Census, to U.S. Department of Commerce 03/27/98
O-98-3 Investment in real property primarily for own use (RCW 31.12.438) 04/01/98
O-98-5 Signature guarantee program 04/20/98
O-98-7 Disclosure of records to state law enforcement agencies 04/23/98
O-98-6 Approval of Progressive Financial Institutions Bond 06/24/98
O-98-8 Control of non-profit charitable organization 07/09/98
O-98-9 Taking former employees of occupational group as members 08/14/98
O-98-10 Effective date of credit union mergers 08/14/98
O-98-11 Canceled
O-98-12 Definition of "voluntary committee" 12/30/98


1997 Interpretive Letters

Number Subject Date
O-97-1 Cancelled 01/07/97
O-97-5 Investment in Federal Home Loan Bank bonds 01/30/97
O-97-2 Incidental powers of credit unions with regard to charitable or community contributions 02/21/97
O-97-3 Federal parity for state credit unions; NCUA Part 741; supervisory committees and member business loans 03/11/97
O-97-4 Authority of state chartered credit union to conduct business on overseas military installations 03/24/97
O-97-6 Gifts for retiring directors and supervisory committee members 04/11/97
O-97-7 Political contributions 04/14/97
O-97-8 Canceled
O-97-9 Maintenance of WCUSGA reserves after a merger into a NCUSIF insured credit union 05/27/97
O-97-12 Disqualification of director for absence 06/04/97
O-97-10 Maintenance of WCUSGA reserves after conversion to NCUSIF 06/17/97
O-97-11 Canceled
O-97-13 Voting rights of Board Chair 07/23/97
O-97-14 Board charge-off of losses 08/11/97
O-97-15 Credit Union Service Organization (CUSO) investment-Changes in ownership and purpose 08/12/97
O-97-16 Transfer of WCUSGA contingency reserve as of December 31, 1998 09/05/97
O-97-17 Effective date of merger of state credit unions or merger of federal into state credit union 09/10/97


1996 Interpretive Letters

Number Subject Date
O-96-1 Response to objections to community FOM application 04/11/96
O-96-2 Requirements for out-of-state credit union to do business in Washington 04/16/96
O-96-3 Provisions applicable to loans to directors, officers, and employees 05/03/96
O-96-4 Exemption from payment of state business and occupation taxes 05/08/96
O-96-5 FOM issues: family members and SOGs 05/09/96
O-96-6 Division does not protect servicemarks 05/13/96
O-96-7 Reimbursement for director’s expense for substitute teacher 06/06/96
O-96-8 Incentive pay for share and deposit accounts 06/19/96
O-96-9 Imaging of documents 08/22/96
O-96-10 Application of Chapter 208-440 WAC to credit union programs 08/26/96
O-96-11 Authority to serve as tax and loan depository for U.S. Treasury 09/06/96
O-96-12 Using SOG procedure to add small occupational groups within 25 mile radius across state lines 09/20/96
O-96-13 Removal of streamlined senior groups from FOM 09/23/96
O-96-14 Loans to credit union employees and officials (Updated-See I-05-02) 10/08/96
O-96-15 Sublease of space to travel agent under Chapter 208-440 WAC 10/29/96
O-96-16 Response to objections to community FOM application 11/25/96
O-96-17 Continued validity of Chapter 208-440 WAC (participation in commercial business activities) 12/03/96
O-96-18 Canceled
O-96-19 Telephone conferencing for board meetings 12/10/96
O-96-21 Payment of membership fee or purchase of shares to join a credit union 12/17/96
O-96-20 Counting mail ballots to reach quorum at membership meeting 12/31/96


1995 Interpretive Letters

Number Subject Date
O-95-1 Direct marketing in FOM community (formally 95-A) 05/18/95
O-95-2 Interpretation of Chapter 419-64 WAC 09/28/95
O-95-5 Response to comment letters on Columbia conversion 09/28/95
O-95-3 Use of the term "credit union" in the name of your company 11/01/95
O-95-4 The Exchange/Electronic Data Systems Corporation- Proposed Joint Venture 11/22/95