Nonmember Loan Issues

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Nonmember Loan Issues

Compliance Couriers

OCU announces it is holding joint borrower letter “in abeyance”

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Federal Regulations

CFPB: 12 CFR 1002._7

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FTC: 16 CFR 444._3

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Federal Statutes

Wis. Stats: 186 Credit Unions (state-chartered only) as regarding accounts and nonmember loans

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Wis. Stats: 186 Credit Unions (state-chartered only) as regarding lending

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Letters to CUs

NCUA: Legal Opinion Letter No. 00-0605 – Permissibility of Nonmember Co-borrower (August 28, 2000)

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NCUA: Legal Opinion Letter No. 95-0616 – Acceptance of Nonmembers as Joint Applicants on a Loan (1995)

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NCUA: Legal Opinion Letter No. 98-0915 – Nonmember Joint Owner’s Ability to Obtain Advances Under an Open End Credit Agreement (November 16, 1998)

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Other

#82028 – Explanation of Personal Obligation (Closed-end) (Rev. 7/23)

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#82077 – Explanation of Personal Obligation (Open-end) (Rev. 7/23)

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#83007 – Notice to Cosigner (Rev. 7/23)

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