Regulatory Alerts2018-11-13 | I-18-04I-18-04 — Loans secured by a 1- to 4-family dwelling and member business lending
The Washington Department of Financial Institutions issued Interpretive Letter I-18-04 to inform state-chartered credit unions that federal law now exempts loans secured by 1- to 4-family dwellings from the definition of member business loans. This exemption applies regardless of whether the property is the member's primary residence, as the Economic Growth, Regulatory Relief, and Consumer Protection Act preempts conflicting state provisions. Consequently, credit unions are authorized to exclude these loans from their aggregate member business lending limit calculations even though state regulations have not yet been formally amended.
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