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CUSO Activities

The following information details the approval process for requesting additional preapproved CUSO activities. Once approved, a list of additional activities and services for natural person CUSOs will be listed on this webpage for any CUSO which desires to engage in those activities. Once an activity is described on this webpage, any CUSO may engage in that activity without further approval from the NCUA.

Overview

Section 712.5 of the NCUA’s regulations lists activities and services preapproved for Credit Union Service Organizations (CUSOs). The specific activities listed within each preapproved category illustrate permissible activities under the particular category and are not an exclusive or exhaustive list. On October 21, 2021, the NCUA Board adopted revisions to its CUSO rule, Part 712. Effective November 26, 2021, those revisions expanded preapproved CUSO activities and services to include the origination of any type of loan that a Federal credit union may originate and granted the NCUA Board additional flexibility to approve permissible activities and services.

Preapproved Activities

Currently, there are no approved activities outside those included in § 712.5. Approved corporate CUSO activities are maintained here.

Approval Process

How to Submit Requests

For NCUA Board approval to engage in activities not otherwise approved in 12 C.F.R. § 712.5, individuals should submit written requests to the attention of the Office of Examination and Insurance.

Requests may be submitted via email to eimail@ncua.gov; or mailed to:

National Credit Union Administration
Office of Examination and Insurance
1775 Duke Street
Alexandria, VA 22314

CUSO activity approval request packages should include, but not be limited to, the following information:

  • A letter requesting approval of the specific CUSO activities with supporting documentation.
  • Detailed description of each specific activity and/or service. Note: Please be specific when describing the activity or service as some activities or services may be referred to generically, but are actually a combination of different activities or services. For example, the term “item processing” can include many different check processing activities. Thus, a request for item processing services must further detail each check processing activity included with the service.
  • Background information on each specific CUSO activity. For example: Who utilizes the activity? How does this activity support the “normal course of business” for credit unions? How many credit unions use the service? Or, for newly proposed activities, how many users are projected to use the service? Include all relevant information that supports the CUSO’s activities.
  • Detailed description of any existing regulatory requirements and surveillance related to the activity or service. Include a description of any standard control structure(s) surrounding each activity or service. For example, Automated Clearing House (ACH) is governed by National Automated Clearing House Association (NACHA) rules and Federal Reserve Bank operating circulars; standard controls include agreements, dual authorization, user, batch, and file limits, day-time constraints, etc.
  • Detailed description of the risks associated with the activity and standard mitigating controls that would minimize or mitigate the risks.
  • Description of necessary staff expertise and experience for managing these activities, services, and associated risks.

Notification of Approval

Individuals requesting approval of service categories or activities will receive written notice of the activities that are approved. As required by the rule, the NCUA will also post approved CUSO activities on the website along with any related restrictions or reporting requirements.

Questions

If you have questions about the approval process or approved activities, please contact the NCUA’s Office of Examination and Insurance at:

National Credit Union Administration
Office of Examination and Insurance
1775 Duke Street
Alexandria, VA 22314

Phone: 703.518.6360
Email: eimail@ncua.gov

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