OGC Op. 99-0426 (May 5, 1999)

[redacted]
[redacted] Federal Credit Union
[redacted]
[redacted]

Re: Definition of Household Members for Field of Membership, Your letter dated April 9,1999.

Dear [redacted]:

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,

/s/

Sheila A. Albin
Associate General Counsel

GC/MJMCK:bhs
SSIC 6100
99-0426

Last modified on
07/27/20