January 9, 1998

David H. Bussard, President
Giant Food Federal Credit Union
11785 Beltsville Drive
Beltsville, MD 20705-3147

Dear Mr. Bussard:

You have asked for the Office of General Counsel to advise you about whether your FCU can change its bylaws to allow it to operate under two names. An FCU cannot have two charter names. An FCU can adopt a trade name for use in advertising but its official charter name must be used in all official or legal communications or documents.

Your sponsor, Giant of Maryland, Inc., operates retail grocery stores under the "Giant" name in Maryland, Virginia, and the District of Columbia and under the "Super G" name in Pennsylvania, New Jersey, and Delaware. The "Super G" name is used to avoid conflicts with an existing grocery store chain in those states with the name "Giant of Carlisle, Inc." Your sponsor's legal counsel advised the FCU to discontinue using the "Giant" logo on any printed materials (e.g., newsletters, applications, marketing materials, and forms) used in the "Super G" states. In response to this request, your FCU uses the "Super G" logo in those states. Your FCU would like to use the name "Super G FCU" in "Super G" states to foster membership recognition and because you are concerned about a potential legal challenge to your use of "Giant" logo by the other grocery store chain.

NCUA's policy on charter names is set out in the NCUA Chartering and Field of Membership Manual. Interpretive Ruling and Policy Statement No. 94-1, Chartering and Field of Membership Policy, Ch. 1, Section VI, 59 Fed. Reg. 29066, 29083 (June 3, 1994)(attached). An FCU can have only one charter name. However, as discussed in the enclosed letter from me to Ron Martin, dated September 22, 1997, an FCU may use a tradename in advertising.

Sincerely,

Sheila A. Albin
Associate General Counsel

GC/MSC:sg
SSIC 4690 / 97-1060

Enclosure

cc: Region II