NCUA FOM – Does “vendor/supplier” for TIP Charter include contractors?

Compliance > NCUA
Q:  Does “vendor/supplier” for TIP Charter include contractors?
A:  It depends.  It may include, on a case-by-case basis, employees of types of entities that have a “strong dependency relationship” and work directly with other types of entities within the industry.  A “strong dependency relationship” between a TIP entity and its supplier/vendor must be demonstrated by the reliance on each other as measured by the presence of indicators of a likelihood that the absence of one would cause the other to suffer a material decline in either revenue, functionality, or productivity.  A credit union seeking to include “vendors/suppliers” to an Industry type TIP must provide a narrative identifying indicators that support the existence of the strong dependency relationship between the TIP entity and its individual supplier/vendors.      
This information was obtained from the NCUA’s website, Chartering and Field of Membership Resources page -

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