June 25, 1998
John U. Barker, Manager
Hudson River Teachers Federal Credit Union
2085 East Main Street, RT #6
Cortlandt Manor, New York 10566
You have asked for the authority for the provision in the Accounting
Manual for Federal Credit Unions (Accounting Manual) that requires
federal credit unions (FCUs) to retain individual statements or
ledgers for share and loan accounts permanently. Accounting Manual,
§5190.3(h). The Accounting Manual generally represents agency
policy, not law or regulation.
The Accounting Manual "is not incorporated by reference in
the NCUA Rules & Regulations" and, except for Section
2000 that addresses full and fair disclosure required by regulation,
"is intended to provide guidelines . . . with information
on recommended procedures and practices." Accounting Manual,
§1010.1 (copy attached). You may find the attached letter
from James J. Engel to Mark Baron dated September 10, 1991, helpful.
It reiterates that the Accounting Manual is NCUA policy as opposed
to law or regulation and discusses various considerations in connection
with retention of records.
Sincerely,
Sheila A. Albin
Associate General Counsel
GC/MFR:bhs
SSIC 3500
98-0603
Enclosures