National Credit Union Administration (NCUA) Chair Kyle Hauptman has clarified that credit unions are not prohibited from serving unhoused veterans under existing Bank Secrecy Act/Anti-Money Laundering (BSA/AML) requirements and Customer Identification Program (CIP) regulations.
In a letter to the Defense Credit Union Council (DCUC) regarding an inquiry about extending authority to credit unions to serve unhoused veterans, Chair Hauptman stated that no such extension is necessary, as the current regulatory framework already permits such service within a credit union’s field of membership.
The letter, responding to a DCUC inquiry from February 10, addressed concerns related to CIP requirements, which mandate credit unions gather identifying information, including a physical address, from potential members.
Hauptman highlighted that under CIP regulations (31 C.F.R. § 1020.220), credit unions are required to have risk-based procedures for identity verification and that the rules provide examples of both documentary and non-documentary methods. He specifically noted: “Nothing prohibits credit unions from implementing a CIP policy that allows the use of a Veteran’s Affairs (VA) photo identification to assist in verifying the identity of their members.”
The letter also clarifies the address requirement (31 C.F.R. § 1020.220(a)(2)(i)). While a physical address is required, the regulation “permits individuals who do not have a residential or business street address to use the residential or business street address of another contact individual.”
Hauptman also provided a practical example relevant to veterans: “If a VA caseworker intends to serve as an unhoused veteran’s contact, the address requirement could be satisfied with the VA caseworker’s office street address, which the credit union would use to contact the member/veteran.”
The NCUA chair emphasized the agency’s support for credit unions utilizing flexible, risk-based BSA/AML policies and CIP procedures that “facilitate unhoused veterans’ access to the financial system.”
The letter emphasizes that current regulations are designed with enough flexibility to allow credit unions to serve individuals, including unhoused veterans, who may not have traditional housing, provided identity and contact information can be verified through alternative, risk-based methods permissible under the rules.
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