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Regulatory Relief Measures

Due to the impact of COVID-19, multiple regulatory agencies are issuing relief that may impact the credit union. 

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Regulatory Relief Measures: Board Meetings

The NCUA issued a letter to credit unions on March 20, 2020 that allows a federal credit union to adopt by a two-thirds vote of its Board of Directors a bylaw amendment to Article IV without going through the formal bylaw approval process with the NCU The bylaw option, which is provided in detail below, allows for the annual meeting to be conducted virtually.

Section 6. Emergency exception to in-person quorum requirement. This credit union may hold its annual meeting of the members, and special member meetings for authorized purposes other than member expulsion under Article XIV of these bylaws, virtually (webcasts, teleconferences, virtual meeting rooms or similar means that permit members to listen, vote as necessary and participate) and without an in-person quorum if all of the following conditions apply and are certified in meeting minutes by a resolution of the majority of a quorum of the board of directors:

  • At least one of the following is located in an area where a federal, state, or local authority has declared a state of emergency or major disaster:
    1. all or part of a community the credit union serves; or
    2. the credit union’s headquarters.
  • The credit union has the technological capacity to facilitate virtual meeting attendance, voting, and participation.
  • Members receive at least seven days’ advance notice of the change to a virtual meeting format and appropriate instructions for how to join, participate, and vote during the virtual meeting.
  • The NCUA has issued general or specific guidance notifying the credit union that it is appropriate to invoke this bylaw provision.

An additional option for the credit union may be a delayed annual meeting. The credit union has the ability to postpone its annual meeting date, providing notice

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Regulatory Relief Measures: Model Policies

The following policy from CU PolicyPro can be used to help you craft your own policy on this topic:

We recommend reviewing your own policies to see if this policy or similar policies have already been customized and are in use by your credit union. If you're not sure if your credit union subscribes to CU PolicyPro, contact policysupport@cusolutionsgroup.com for assistance.

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Regulatory Relief Measures: Shared Branching

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