Jo Ann Broderick, President/CEO
First Commonwealth Federal Credit Union
P.O. Box 20450
Lehigh Valley, Pennsylvania 18002

Re: Federal Credit Union Bylaws on Voting.

Dear Ms. Broderick:

You have asked us to interpret the phrase "24 hours" in one of the Federal Credit Union Bylaws that provides for elections of directors through the use of ballot boxes or voting machines. The bylaw provides:

After the members have been given 24 hours to vote at conspicuous locations as determined by the board of blockquoteectors, the ballot boxes or voting machines will be opened, the vote tallied by the tellers, the tallies placed in the ballot boxes, and the ballot boxes resealed.

Federal Credit Union Bylaws, Art. V, Section 2(c), Option A3. Under this option, members also have the opportunity to vote in person at the annual election. The opportunity to vote before the annual meeting at a ballot box provides an additional opportunity for the member to participate.

NCUA maintains that bylaws are a contract between a federal credit union (FCU) and its members to be interpreted under state law. We believe that, in the context of this bylaw provision, the phrase "24 hours" should be read literally. Members should have access to ballot boxes over any 24 hours identified by the board of directors. Therefore, the FCU may opt to make its ballot boxes or voting machines available to its members over 24 consecutive hours or it may choose to divide the 24 hours to vote over several days. In determining an appropriate election procedure, the FCU should consider member convenience and preserving the integrity of the voting process. We hope you find this guidance helpful.

GC:CJL/bhs
SSIC 3700
00-0134