ALEXANDRIA, Va. — NCUA clarified in a recent legal opinion letter (06-1101) that federal credit unions may establish no-interest/dividend accounts for members lacking Social Security numbers or another taxpayer identification number.
Federal credit unions still must comply with all Truth in Savings Act disclosure and notice requirements, NCUA Associate General Counsel Sheila Albin cautioned in the letter. Additionally, she wrote, "Without a TIN or SSN, federally insured credit unions must also ensure their customer identification program adequately addresses the documentation required for compliance with requirements of the Bank Secrecy Act."
State-chartered credit unions should contact their state supervisory agency on whether this arrangement is permissible and, if so, must comply with TISA as well.
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