Letter to Credit Unions No.: 16-CU-02 On-Line CUSO Registry to Open for Registrations in February
January 2015

NCUA published LTCU 16-CU-02 to inform credit unions that NCUA’s CUSO Registry will be available for CUSO to begin reporting information directly to NCUA on February 1, 2016. CUSO will have 60 days, until March 31, 2016, to complete their initial registration and reporting.

How does this affect my credit union?
FISCUs are required to enter into written agreements with any CUSOs they make loans to or invest in that obligates the CUSO to annually provide certain information directly to NCUA, and the state supervisory authority through the CUSO Registry. The requirement applies to all tiers and subsidiaries of CUSOs as well. These requirements, found in Part 712 of NCUA’s rules, do not apply to credit unions that only receive services from a CUSO, but do not lend to, or invest in, CUSOs.

If a CUSO fails to register, credit unions may not make additional investments or loans to the CUSO until the CUSO satisfies the annual registration requirement. By mid-2016, credit unions will be able to verify thru the NCUA’s CUSO Registry whether a particular CUSO is in compliance.

How will NCUA enforce CUSO registration requirements?
NCUA examiners will review credit unions’ compliance with the CUSO rule during the examination process. If NCUA identifies a CUSO that has failed to satisfy the annual registration requirement, NCUA will notify the CUSO of the need to register, and the CUSO will then have 30 days to complete registration before NCUA notifies credit unions that any new investments and loans to the unregistered CUSO are impermissible.

How will the registration process for CUSOs proceed?
NCUA recently contacted over 600 known CUSOs, requesting the confirmation of CUSO employee identification numbers (EINs) that NCUA had on file. After February 1, 2016, when the CUSO Registry becomes available, NCUA will also make training material available  to support the Registry at https://cusoregistry.ncua.gov.

CUSOs seeking more information may contact NCUA at (800) 827-6282 (x 6360) or at CUSORegistry@ncua.gov.

As noted above, after the close of registration on March 31, NCUA will contact any known CUSOs that failed to complete the registration process and give them an opportunity to come into compliance. After that, NCUA will contact any credit unions that have made a loan to or investment in the CUSO to alert them to the CUSO’s status, and prohibit further loans or investments. After this process is complete, NCUA will prepare the CUSO Registry data for public release. NCUA anticipates this will be completed by June 1, 2016.

 

Will NCUA protect confidential information provided by CUSOs?
Some information reported by CUSOs will be publicly accessible, such as the CUSO’s name, services provided, address and other contact information. However, trade secrets and privileged or confidential commercial or financial information will not be publicly accessible through the CUSO Registry.

State Regulators
NCUA will only share CUSO Registry information with state supervisory authorities that have signed written information sharing agreements with the agency.

 

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