Dear Mr. Lee:
You have asked whether a federal credit union (FCU) can use the names of its sponsor's subsidiaries to name its branch offices. Yes, FCUs can operate branch offices under a different name than the name of the insured credit union if the FCU takes reasonable steps to ensure members are fully apprised of the use of different names.
In NCUA Letter to Credit Unions No. 99-CU-17 (Letter No. 99-CU-17), issued in October 1999,
NCUA provided guidance to credit unions about the use of multiple names. Further, NCUA’s
regulations prohibit federally-insured credit unions from using any advertising, displays, signs,
stationery, or other promotional material that is “inaccurate or deceptive in any particular.”
12 C.F.R. §740.2. To ensure an FCU’s advertising is not inaccurate or deceptive, it should review
the several steps Letter No. 99-CU-17 lists that FCUs should undertake. In particular, FCUs should
ensure signage used at a branch office under a different name clearly reflects the branch office is
a division or branch of the same insured credit union. We advise you to review Letter No. 99-CU-17
to ensure your members are accurately apprised of the use of multiple names.
Finally, an FCU should obtain written permission from its sponsor before using the names or
trademarks of the sponsor's subsidiaries. If you have any further questions, please contact Staff
Attorney Justin Anderson at 703/518-6540.