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ALEXANDRIA, Va.-In a recent legal opinion letter (03-0964), NCUA stated that it is permissible for a federal credit union to rely on individual taxpayer identification numbers (ITINs) and the matricula consular identification cards or state identification cards to open a loan account. According to the letter, the board of Chicanos Por La Causa Federal Credit Union in Phoenix recently approved a program to help members without social security numbers establish a credit history. Previously, the credit union accepted the matricula consular to open share and share draft accounts. The credit union plans to run credit checks and report account activity to credit reporting agencies. “We are aware of no law that prohibits a creditor from reporting borrower data by an identification number other than the social security number,” NCUA Associate General Counsel Sheila Albin wrote. “Further, although the credit reporting agencies more frequently maintain information by an individual’s social security number, we know of no law that prohibits them from maintaining information by another identification number as long as they comply with the Fair Credit Reporting Act’s provisions requiring that they have reasonable procedures to assure the information’s maximum possible accuracy.” Additionally, Albin said La Causa Federal Credit Union’s Board must ensure that its policies and procedures identify and address the risks associated with the new activities. The issue arose during a Partnering and Leadership Successes workshop in Durham, N.C. this summer on connecting with the Latino community. NCUA Board Member Debbie Matz, who spearheads the PALS program, acknowledged that credit union boards are free to set their own policies in this regard, but “If you really want to make headway in the Hispanic community, you really need to do this.” She added that some credit union officials at the workshop were still wary of accepting the matricula consular for identification.

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