Serving Non-Members

The Washington State Legislature passed HB 1165, which made several changes to the Washington State Credit Union Act. The changes are effective June 9, 2022. One of those changes allows credit unions to serve certain non-members in a limited capacity.

Washington State credit unions can “cash checks, money orders, and other payment instruments for members and persons who are eligible for membership in the credit union.” [RCW 31.12.402] DCU Bulletin B-22-03 states that credit unions are still expected to follow FinCEN guidelines as it related to BSA and OFAC requirements. Credit unions can impose reasonable charges for cashing these items.

Credit unions should understand that the provisions only apply to:

  • State-chartered credit unions. Federal credit unions can only provide services to their members.
  • Cashing checks, money orders, or other payment instructions. It does not include other services the credit union might offer.
  • Non-members who are eligible for membership in the credit union. Not everyone will be able to take advantage of this.

A credit union wishing to do this should have an approved policy stating what types of items the credit union will cash, fees for cashing the items, and what it will accept to verify the identity of the payees. Fee schedules should be available to eligible non-members before they cash an item.

If you have any questions, contact us.

Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.

 

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