ALEXANDRIA, Va. - NCUA stated in a recent legal opinion letter(04-0257) that federal credit unions may require joint accountowners to set up separate membership accounts. However, if thecredit union has adopted the October 1999 Federal Credit UnionBylaws, the provision addressing joint membership must be deleted,which NCUA does not have to approve. As an alternative, though,NCUA Associate General Counsel Sheila Albin suggested theinstitution ask for NCUA approval for a bylaw amendment "as this isa significant condition of membership and, although not required tobe in the bylaws, we think it should be." Under the Bylaws, theletter read, "Owners of a joint account may both be members of thecredit union without opening separate accounts." However, Albinacknowledged, "We understand that FCUs may want to requireindividual accounts for each member because of data processingconstraints or operational issues." Legal opinion letter 00-0555,Nonstandard Bylaw Amendment, dated June 14, 2000, which discussesdeleting this provision, is available on NCUA's Web site.

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