WASHINGTON, D.C (May 7, 2025) |
The Defense Credit Union Council (DCUC) commends the National Credit Union Administration (NCUA) and Chairman, the Honorable Kyle Hauptman, for the timely and thoughtful response to DCUC’s February 10, 2025, letter requesting regulatory clarity on the ability of credit unions to serve unhoused veterans. See the NCUA letter here.
DCUC’s letter noted the need for parity with the Federal Deposit Insurance Corporation (FDIC), which has already provided similar guidance to banks following outreach from the Association of Military Banks of America (AMBA). This FDIC guidance has empowered banks to support veterans experiencing homelessness—a critical step endorsed by the Department of Veterans Affairs (VA). DCUC urged the NCUA to affirm credit unions’ authority to take similar action.
In its official reply, the NCUA confirmed that credit unions are not prohibited from offering financial services to unhoused veterans under current Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and Customer Identification Program (CIP) requirements.
“Under CIP regulations, 31 C.F.R. § 1020.220(a)(2), credit unions are required to have risk based procedures for verifying the identity of each member to the extent reasonable and practicable. The regulation offers documentary and non-documentary examples of how a credit union could reasonably verify a member’s identity. Nothing prohibits credit unions from implementing a CIP policy that allows the use of a Veteran’s Affairs (VA) photo identification to assist in verifying the identity of their members.
Further, 31 C.F.R. § 1020.220(a)(2)(i) of CIP regulations requires credit unions to obtain certain information, including a physical address, from each member prior to opening an account. It permits individuals who do not have a residential or business street address to use the residential or business street address of another contact individual. If a VA caseworker intends to serve as an unhoused veteran’s contact, the address requirement could be satisfied with the VA caseworker’s office street address, which the credit union would use to contact the member/veteran.
NCUA supports credit unions’ ability to create effective, risk-based BSA/AML policies and CIP procedures that facilitate unhoused veterans’ access to the financial system,” wrote Chairman Hauptman.
NCUA’s response affirms that credit unions may develop risk-based CIP policies that include using VA-issued photo identification and the address of a VA caseworker or office as part of a valid method to verify identity and establish accounts for unhoused individuals.
“This is a meaningful step forward,” said Anthony Hernandez, DCUC President/CEO. “By clarifying that existing regulations already allow credit unions to serve unhoused veterans, the NCUA and Chairman Hauptman have removed a significant barrier to access and ensured that those who served our nation can rely on trusted financial institutions during times of transition. We are grateful to Chairman Hauptman for his response and commitment to supporting those who have served our nation. This clarity is not just a regulatory interpretation—it is a recognition of the moral imperative to serve those who sacrificed for our country.”
Why This Matters
Many unhoused veterans lack the documentation or permanent address required to access traditional banking services. Without access to a checking or savings account, veterans may be unable to receive their VA benefits, make secure housing payments, or begin the process of rebuilding credit. NCUA’s clarification ensures credit unions can confidently step in to fill this gap, providing a pathway toward financial stability and independence.
This also brings credit unions in line with guidance already issued to banks by the FDIC, promoting regulatory parity and ensuring fairness in how institutions support vulnerable populations.
DCUC has long emphasized that “defense credit unions”—institutions dedicated and rooted in serving military populations—are uniquely positioned to meet the needs of service members, veterans, and their families. These credit unions often operate on or near installations, maintain strong relationships with base populations, and deeply understand the financial stresses and unique needs associated with service.
Thanks to the NCUA’s clear and proactive guidance, credit unions can confidently extend this trusted support to veterans facing homelessness—aligning with broader efforts by the VA and federal agencies to combat veteran homelessness and promote long-term economic security.
“We appreciate the leadership and foresight shown by Chairman Hauptman and the NCUA,” said Jason Stverak, DCUC Chief Advocacy Officer. “By confirming that unhoused veterans can be served under existing CIP regulations, the NCUA has empowered credit unions to confidently take action that aligns with both their mission and the values of the military communities they serve. We look forward to working closely with our member credit unions to implement these policies and ensure that no veteran is left behind when it comes to financial access.”
For more information, please contact Jason Stverak at jstverak@dcuc.org and visit dcuc.org/advocacy.