Third party relationships can present great opportunities to credit unions to meet their strategic goals and to expand member services in an increasingly competitive marketplace. However, these opportunities must be properly evaluated, with risks assessed and adequately mitigated. This webinar reviews the NCUA’s supervisory guidance as to how credit unions should evaluate their third party […]
By: Michael Mulvey mmulvey@cusolaw.com One of the benefits of forming a CUSO is the limited liability protection offered to a CUSO’s investor(s). In order to maintain this protection, the CUSO and investing credit union(s) must maintain corporate separateness. This means the two entities’ operations are separate and distinct from each other. The reason this […]
By: Michael Mulvey mmulvey@cusolaw.com For our blockchain or cryptocurrency enthusiasts out there: Following the downfall of FTX and subsequent hearings in December, Senators Elizabeth Warren and Roger Marshall introduced the Digital Asset Anti-Money Laundering Act authorizing rule making, risk-focused examination and review processes and reporting for federal agencies. SIL22D55 (senate.gov) Additionally, the New […]
By: Michael Mulvey mmulvey@cusolaw.com In November 2021, the NCUA expanded the lending capabilities of CUSOs. CUSOs can now engage in all types of lending permitted for federal credit unions. The NCUA recently released a letter to credit unions providing guidance on the CUSO lending rule now that the rule has been in effect for […]
Leveraging the Profits Made by CUSOs The primary advantage to using a holding company CUSO is a consolidation of CUSO investments and leveraging the profitable CUSOs to make additional CUSO investments. A federally chartered credit union may only invest up to 1% of its assets in CUSOs in the aggregate. However, NCUA defines CUSO investment […]
As you know, part of forming a credit union service organization (“CUSO”) involves registering the company on the National Credit Union Administration’s (“NCUA”) CUSO Registry. Within sixty (60) days of the first credit union making an investment in the CUSO, the CUSO must register with the NCUA. The web-based registration process takes approximately fifteen minutes […]
