The Washington Department of Financial Institutions' Division of Credit Unions issued an interpretative letter to Washington State Employees Credit Union on whether a former credit union member can be re-instated as a member under the "once a member, always a member" principle, although the person no longer meets the field of membership requirements.
The interpretative letter states that "the principle does not provide re-instatement for an individual after he terminated his membership with the credit union and no longer meets the field of membership requirements."
However, the letter does point out that if the account closing was solely a mistake of the credit union, the credit union can re-instate a former member as long as the credit union had once a member, always a member policy in place at the time the accounts were closed. The credit union will need to document the nature of the mistake.
This interpretative letter is consistent with a legal opinion letter issued by NCUA in 1991.
Read the Washington DFI letter.
Read NCUA's 1991 letter.
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Once a Member is a policy from the early days of closed CU FOM's. Members were allowed to keep their account even if they left the FOM because of transfer or change of job. It was never meant to apply to closed accounts. Every new member had to qualify based upon their current situation and meeting the requirements of the cu's FOM. There is nothing new here.
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