May 5, 1999
Suzanne Turner, Compliance Officer
Redstone Federal Credit Union
220 Wynn Drive
Huntsville, Alabama 35893
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