ALEXANDRIA, Va.–NCUA has 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.
The clarification came in response to a request from the Defense Credit Union Council regarding the ability of credit unions to serve unhoused veterans. See the NCUA letter here.
In its initial letter, DCUC said there was a 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 said.
“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 agency said in its response. “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.”
Additional Clarity
In addition, NCUA told DCUC 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,” according to the agency. “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 Chairman Kyle Hauptman wrote that the agency supports credit unions’ ability to create effective, risk-based BSA/AML policies and CIP procedures that “facilitate unhoused veterans’ access to the financial system.”
Affirmation Provided
DCUC said 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,” Anthony Hernandez, DCUC President/CEO, said in a statement. “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 It Matters
According to DCUC, 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,” DCUC said. “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 added.
Long-Time Emphasis
DCUC said it 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,” the organization stated.