Banking Law 451
September 30, 2004
To: Examiner Frances Wellman
From: Harry C. Goberdhan - Legal Division
Subject: Sponsor - organization becoming member
According to your Memorandum dated August 31, 2004, [ ] is a sponsor of the [ ], and wants to become a member of [ ]in order to be able to use [ ] services - make deposits, withdrawals and/or open a checking account.
Banking Law §451(e) permits "any incorporated or unincorporated organization composed principally of persons eligible to membership" to become a member of a credit union; provided, however, that such membership is "not expressly prohibited by the bylaws of the credit union."
In this case, [ ] is an organization composed principally of persons eligible to membership in [ ]; also, the Bylaws of [ ] do not prohibit such membership. The Banking Laws were also reviewed in order to determine whether there are any prohibitions on a "sponsor" becoming a member: no Banking Laws were found that prohibit such membership.
In light of the above, [ ] can become a member of [ ], and the Department would take no action against such membership.