Last week, NCUA issued a LOL (legal opinion letter. Not laugh out loud. Come on, people!) to clarify what constitutes a "service facility." More specifically, NCUA clarified that a website just doesn't cut the mustard.
The current Chartering Manual definition of service facility provides multiple common bond credit unions with several options for the types of facilities it can use to serve its occupational and associational groups. A credit union’s Internet website lacks a physical presence so cannot meet the statutory requirement to be within reasonable proximity of the groups.
If you serve multiple occupational and/or associational groups, this legal opinion letter provides a good overview of "service facility" requirements. Access the letter here.
Here's a link to the most recent NCUA newsletter. These newsletters do a good job of highlighting recent developments. But they also contain an order form for NCUA documents and publications.
Yes, my Steelers did win last night. Here are my three rules to obey when your team wins the Super Bowl.
- You may not gripe about your team in any way for 5 years.
- Do not buy Super Bowl merchandise. It will be tempting. But it becomes dated. And believe me, no one else cares that your team won the Super Bowl.
Refrain from talking about the game with fans of other teams. If they bring it up, simply state that you're happy to get the win and that you're glad that you don't have to play them again. If you start talking about the game beyond that, you'll say something stupid. Believe me, I know from experience.