May 21, 1998



Mr. Marc Shafroth
CUNA - Economics & Statistics Department
5710 Mineral Point Road
Madison, Wisconsin 53705-4454

Re: IRS Form 990 Filing Requirement for Federal Credit Unions.

Dear Mr. Shafroth:

You have written to request information concerning Internal Revenue Service (IRS) Form 990, which is an informational return required to be filed by certain tax-exempt organizations. You indicated that a CPA firm contacted you and asked whether NCUA files a consolidated Form 990, and if so, if it uses year-end call report data. Federal credit unions (FCUs) are not required to file a Form 990.

Prior to 1988, NCUA had filed a consolidated Form 990 for all FCUs. In 1988, in response to an NCUA inquiry, the IRS responded that FCUs are not required to file a Form 990. NCUA addressed the issue of filing a consolidated Form 990 in its Letter No. 100 to Credit Unions, dated October 27, 1988, a copy of which is enclosed for your reference. Also included is the attachment to Letter No. 100, which is the letter to NCUA from the IRS explaining its determination.

Sincerely,

Sheila A. Albin
Associate General Counsel

OGC/DMS:bhs
SSIC 3210
98-0435
Enclosure