March 26, 1999
Paul V. Parrish, President/CEO
NWA Federal Credit Union
4 Appletree Square
Bloomington, Minnesota 55425-1642
Dear Mr. Parrish:
You have asked us to reconsider our June 10, 1992, opinion regarding
the reimbursement of child care expenses incurred by a volunteer
member of the board of directors when attending board meetings.
We continue to believe that child care expenses are not permissible
under our regulation limiting compensation to credit union officials.
NCUA regulations provide that only one board officer may be compensated
as an officer of the board but permits reimbursement of "reasonable
and proper costs" that are determined to be "necessary
or appropriate in order to carry out the official business of
the credit union." 12 C.F.R. §701.33(b)(2)(i). You
believe that to attract and retain good volunteers a federal credit
union should be able to reimburse its volunteers for the child
care expenses they incur in carrying out the duties of their volunteer
positions.
As discussed in the June 10, 1992 letter referenced above, the
NCUA Board previously considered expanding the area of permissible
reimbursement when amendments to this regulation were proposed.
Comments from credit unions persuaded the Board that to do so
was unnecessary and could lead to an array of problems. Our view
is that payment of child care expenses, like reimbursement for
lost leave or pay for volunteers who take time away from their
jobs to attend to credit union business, would violate NCUA's
regulation. Our understanding is that many credit unions accommodate
volunteer officials by scheduling meetings at times that are the
least disruptive to work or child care schedules.
Sincerely,
Sheila A. Albin
Associate General Counsel
GC/SAA/NSW:bhs
SSIC 3500
98-1215