April 14, 1997

Kirsten S. Moy, Director
Community Development
Financial Institutions Fund
Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220

Dear Ms. Moy:

We are providing the following legal opinion based on our understanding that it will be helpful to federal credit unions that are applying for grants from the Community Development Financial Institutions Fund (the Fund).

It is the opinion of the Office of General Counsel that federal credit unions may engage in the activities of the Fund's program and may lawfully execute the Fund's assistance agreements. In reaching this opinion, we have reviewed a draft of the "Community Development Financial Institutions Program Assistance Agreement for Grants to Insured Credit Unions;" the Community Development Banking and Financial Institutions Act of 1994, 12 U.S.C. §§4701-4750; and the Community Development Financial Institutions Program Regulations, 12 C.F.R. Part 1805. We have also considered whether the Federal Credit Union Act, 12.U.S.C. §1751 et seq., or any of the National Credit Union Administration's Rules and Regulations prohibit a federal credit union from participation in the Fund's programs or execution of the agreement. We have concluded they do not. Our opinion is limited as stated and is not intended to provide an opinion on any other matters relating to the Fund or its agreements

Sincerely,

Sheila A. Albin
Acting Associate General Counsel

GC/MSC:sg
SSIC 4016
97-0328

cc: Joyce Jackson, Director OCDCU