Revised Interpretive Statement Regarding the Use of Trade Name in lieu of Official Charter Name

On January 3, the DCU released an updated Interpretive Statement in relation to advertising restrictions imposed on a credit union if it acts as an investment adviser, or if it aces pursuant to any other superseding or preemptive law or regulation subject to any other agency than the DCU.

The original Interpretive Statement, and this Revised Statement result from Washington State chartered credit unions asking whether it is permissible for them to use a trade name or “dba” when conducting business with members and the public.

The Statement discusses the requirements of using a trade name in lieu of, and in contemporaneous use of the official charter name when conducting credit union business.  But when the credit union is engaged in investment advice or other activities that are ruled by an agency other than the DCU, the credit union must follow those rules.  Such as, the Washington Securities Act requires the credit union to use its official charter name when acting as an investment adviser.

Credit unions that use a trade name, other than its official charter name, should review the Interpretive Statement for requirements.

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