Mr. Walter Polner, Director of Research
ASCU
P.O. Box 5488
Madison, Wisconsin 53705

Dear Mr. Polner:

Chairman D'Amours forwarded your letter to the Office of General Counsel for response. We apologize for the delay in our reply, however, we did not receive your letter until October 10, 1997. You have asked whether immediate family members, who have joined a federal credit union (FCU) through their relationship to an individual within the FCU's common bond, may continue their membership once that individual is deceased. They may maintain their membership at an FCU provided the FCU has adopted a "once a member always a member" bylaw provision. The FCU need not take any other action to allow for such membership to continue. For further guidance, please see letter from Hattie M. Ulan to Larry J. Cox, dated January 17, 1992 (attached).

Sincerely,

Sheila A. Albin
Associate General Counsel

GC/NSW:bhs
SSIC 6010
97-1019