Financial Services Superintendent Maria T. Vullo today announced that the Department of Financial Services (DFS) has issued guidance declaring that New York State-chartered credit unions seeking to establish temporary facilities in New York to provide limited services that do not include certain monetary transactions, such as signing up new members, may provide such services on notice to DFS without requiring a prior application with DFS. Under the new guidance, credit unions must provide the Department a schedule listing upcoming times and locations of the temporary facilities, as well as the number and title of qualified individuals offering the services at any temporary facility located in New York, and any further information as the Department may require. These facilities can include mobile service units, tents, booths, tables, or similar stations.

"Temporary facilities can be useful tools for New York State-chartered credit unions to better service their existing members, attract new members, and extend the provision of financial products and services to underserved communities in New York State in an efficient manner," said Superintendent Vullo. "The Department remains committed to assisting the continued expansion of New York State-chartered financial institutions that offer vital resources to local communities and contribute to regional economic growth while providing strong state-based consumer protection through regulatory oversight by DFS."

This new guidance was developed after DFS learned that there may be a question as to whether state-chartered credit unions are required to seek the Department's approval if they use temporary mobile service units, tents, booths, tables or similar temporary facilities located in New York to sign up new members; receive loan and credit card applications; and/or advise members and potential members about the products and services offered by the credit union, provided they do not include or involve any wire transfer transactions, accepting or contracting for deposit type liabilities, withdrawals, dispersing, remitting or transmitting funds, issuing ATM, debit or credit cards, processing or executing any form of loan or financing, or accepting any payments.

The credit union must provide the Department with information regarding the security procedures for the protection of confidential information and data. In addition, the credit union is required to obtain any permit or authorization that may be required from any city or local governmental agency for operation or use of the temporary facility and conspicuously display the name and signage of the credit union on the temporary facility.

As with all other activities of state-chartered institutions, DFS requires that all services be conducted in accordance with all applicable New York State and federal laws and regulations, all of which will be subject to examination by the Department.

A copy of the guidance is available here.

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