Dear Ms. Turner:

You have asked whether live-in nannies or domestic workers and foster children qualify as household members under the National Credit Union Administration's Chartering and Field of Membership Manual, Interpretive Ruling and Policy Statement 99-1 (IRPS 99-1). We believe they do.

IRPS 99-1 defines a household as persons living in the same residence maintaining a single economic unit. Chapter 2, Part II.H The preamble published in the Federal Register with the final IRPS 99-1 states that the definition of household includes "any person who is a permanent member of and participates in the maintenance of the household" and "contemplates or intends some permanency and not simply someone who is visiting for a short period." 63 FR 71998, 72005 (December 30, 1998). Our view is that live-in nannies and domestics meet these criteria. The preamble also specifically noted that "[l]egal guardian relationships are considered part of the household definition." Id. We believe that foster children are also part of the household definition due to the legal guardian relationship.

Sincerely,

Sheila A. Albin
Associate General Counsel

GC/MJMCK:bhs
SSIC 6100
99-0426