As we all know, the newly amended CUSO regulation will go into effect on June 30, 2014. On or before that date, federally insured credit unions with investments in or loans to a CUSO must obtain an agreement from such CUSO wherein the CUSO agrees to directly report information to the NCUA. There was some confusion among credit unions and CUSOs whether this regulatory burden extends to credit unions with only a contractual agreement for services with a CUSO. We did not believe that it did or that it should. The NCUA agrees. Attached is a general counsel opinion clarifying this position and explaining the origin of the confusion.