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 to complete.  You are asked to provide the NCUA with information about the CUSO, for example: the credit union investors, who the CUSO’s clients are (if any), the permissible service the CUSO intends to provide, etc.

This year, I am noticing another step in the registration process.  After completing the web-based registration, clients receive an email from a supervision analyst requesting additional information. I put together a sample email below based on what clients have provided me.  If you receive an email from a supervision analyst upon completion of the CUSO registration, please feel free to reach out and I will be happy to assist with appropriate responses.  In the event an analyst is asking for items beyond the scope of the inquiry, you may receive an email that is different than the sample below. If you do, please do not hesitate to reach out. I am curious to see it and help you craft a response.

Sample email:

I am a Supervision Analyst in NCUA’s Western Region office. We received notification that your Company is registering as a credit union service organization (CUSO). Since their EIN has not previously been reported to NCUA by an affiliated credit union, we need to gather additional information about the CUSO to ensure they are a CUSO by regulatory standards before granting access to complete the registration. The Company provided you as someone who could help us with that.

• Can you tell me a little bit about the Company? Who are the owners?
• What types of products or services does the Company offer?
• Who in general are the Company’s customers?
• Where is the main operation center located? 
• Can you confirm that the Company is indeed a CUSO? While not required, it is requested you provide official documentation to validate the authenticity of the CUSO.
• Has there been a financial statement audit of the CUSO, if so what was the effective date of the audit?
• Can you please provide the CUSO’s EIN and EIN confirmation from the IRS?
• Is there any other information you’d like to share about the CUSO?

Michael Mulvey
Messick Lauer & Smith P.C.
mmulvey@cusolaw.com