Rule2026-16030
Purchase, Sale, and Pledge Of Eligible Obligations
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
August 6, 2026
Effective
September 8, 2026
Issuing agencies
National Credit Union Administration
Abstract
This final rule streamlines the NCUA Board (Board)'s regulations governing the purchase, sale, and pledge of eligible obligations. Specifically, the final rule removes the prescriptive lists of items that must be addressed in the written policies adopted by a federal credit union (FCU). Removal of the mandated items will enable a more efficient and principles-based approach. The final rule also removes detailed requirements regarding conflicts of interest and compensation. These regulatory provisions are unnecessary because FCUs are already governed by broader conflict of interest provisions in their bylaws and by the fiduciary duties of their officials. The final rule follows publication of a February 25, 2026, proposed rule and takes into consideration the public comments received on the proposal. After careful consideration of the comments, the Board has decided to adopt the proposed rule without change.
Full Text
<html>
<head>
<title>Federal Register, Volume 91 Issue 150 (Thursday, August 6, 2026)</title>
</head>
<body><pre>
[Federal Register Volume 91, Number 150 (Thursday, August 6, 2026)]
[Rules and Regulations]
[Pages 50680-50684]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-16030]
-----------------------------------------------------------------------
NATIONAL CREDIT UNION ADMINISTRATION
12 CFR Parts 701 and 746
RIN 3133-AF95
Purchase, Sale, and Pledge Of Eligible Obligations
AGENCY: National Credit Union Administration (NCUA).
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: This final rule streamlines the NCUA Board (Board)'s
regulations governing the purchase, sale, and pledge of eligible
obligations. Specifically, the final rule removes the prescriptive
lists of items that must be addressed in the written policies adopted
by a federal credit union (FCU). Removal of the mandated items will
enable a more efficient and principles-based approach. The final rule
also removes detailed requirements regarding conflicts of interest and
compensation. These regulatory provisions are unnecessary because FCUs
are already governed by broader conflict of interest provisions in
their bylaws and by the fiduciary duties of their officials. The final
rule follows publication of a February 25, 2026, proposed rule and
takes into consideration the public comments received on the proposal.
After careful consideration of the comments, the Board has decided to
adopt the proposed rule without change.
DATES: This final rule is effective on September 8, 2026.
FOR FURTHER INFORMATION CONTACT: Ariel Pereira and John Brolin, Senior
Attorneys, Office of General Counsel, at (703) 518-6540 or at 1775 Duke
Street, Alexandria, VA 22314.
SUPPLEMENTARY INFORMATION:
I. Introduction
A. Background
On February 25, 2026, the Board published a proposed rule to
streamline 12 CFR 701.23, which governs the purchase, sale, and pledge
of eligible obligations, for public comment.\1\ The Board proposed to
remove the prescriptive lists of items that must be addressed in the
written policies adopted by an FCU.
---------------------------------------------------------------------------
\1\ 91 FR 9188 (Feb. 25, 2026).
---------------------------------------------------------------------------
Section 701.23 governs the purchase of whole or partial loans from
various sources, including the eligible obligations of an FCU's own
members, student loans, and real estate-secured loans. Paragraph (b)(6)
of Sec. 701.23 provides that the purchases of eligible obligations and
notes of liquidating credit unions must comply with the purchasing
FCU's internal written purchase policies. The paragraph goes on to
mandate a detailed list of requirements for an FCU's internal written
purchase policies. Paragraph (c) of Sec. 701.23 establishes similarly
prescriptive elements that must be addressed in an FCU's written
policies on the sale of eligible obligations. Paragraph (d) does the
same for the required written policy to address the pledging of
eligible obligations.
These requirements, which cover due diligence, risk management,
underwriting, portfolio concentration limits, and legal review, create
a rigid, one-size-fits-all framework that is unduly burdensome,
particularly for smaller FCUs. Section 107(13) of the FCU Act requires
the Board to prescribe ``rules and regulations'' for the purchase,
sale, and pledge of eligible obligations, but does not require the
Board to mandate a detailed framework for internal credit union
policies. Accordingly, the Board proposed revising paragraphs (b)(6),
(c), and (d) of Sec. 701.23 to remove the prescriptive list of items
that must be addressed in the FCU's written policies.
The Board also proposed to remove paragraph (g) of Sec. 701.23,
which establishes a detailed code of conduct regarding conflicts of
interest and compensation. The regulation's broad prohibition on
compensation, followed by a narrow list of exceptions, is inflexible
and may hinder legitimate incentive structures. FCUs are already
governed by broader conflict of interest provisions in their bylaws and
by the fiduciary duties of their officials. The FCU Act does not
require the Board to establish such a detailed compensation framework.
In addition to the substantive amendments discussed above, the
Board also proposed making several technical, non-substantive changes
to the regulations. As a result of the removal of existing paragraph
(g), current Sec. 701.23(h) would be redesignated as Sec. 701.23(g).
A conforming change to the appeals procedures regulation in 12 CFR part
746 was also proposed to reflect this redesignation. Specifically, the
current reference to ``701.23(h)'' in Sec. 746.201(c) would be revised
to read ``701.23(g).''
B. Legal Authority
The Board is issuing this final rule pursuant to its authority
under the FCU Act. Under the FCU Act, NCUA is the chartering and
supervisory authority for FCUs and the federal supervisory authority
for federally insured credit unions (FICUs). The FCU Act grants NCUA a
broad mandate to issue regulations governing both FCUs and FICUs.
Section 120 of the FCU Act is a general grant of regulatory authority
and authorizes the Board to prescribe regulations for the
administration of the FCU Act.\2\ Section 209 of the FCU Act is a
plenary grant of regulatory authority to NCUA to issue regulations
necessary or appropriate to carry out its role as share insurer for all
FICUs.\3\ The FCU Act also includes an express grant of authority for
the Board to subject federally chartered central, or corporate, credit
unions to such rules, regulations, and orders as the Board deems
appropriate.\4\
---------------------------------------------------------------------------
\2\ 12 U.S.C. 1766(a).
\3\ 12 U.S.C. 1789.
\4\ 12 U.S.C. 1766(a).
---------------------------------------------------------------------------
II. Final Rule
When the public comment period ended on April 27 2026, the Board
had received 15 public comments on the proposed rule. Comments were
received from individuals, a nonprofit advocacy
[[Page 50681]]
organization, credit unions, state credit union leagues, national trade
associations, and a national association of state credit union
supervisors. After careful consideration of the issues raised by the
commenters, the Board has decided to adopt the proposal without change.
The following sections of this preamble summarize the significant
issues raised by the commenters, and NCUA's responses to these issues.
A. Support for Proposed Rule
Nine of the commenters offered unqualified support for the proposed
rule. The commenters wrote that the regulatory changes would reduce
compliance burden on FCUs. The commenters appreciated the flexibility
provided by the proposed rule, which would enable FCUs to develop
written policies appropriately scaled for their operations, while not
increasing safety and soundness risks. The commenters also agreed with
the removal of the conflict-of-interest and compensation provisions
because these matters are already governed by FCU bylaws and fiduciary
duties.
NCUA Response. The Board appreciates the support of the commenters.
As noted, the Board has decided to adopt the proposed rule without
change. The Board continues to believe that an FCU's board is in the
best position to develop policies that are appropriately scaled for its
activities. Although FCUs would still be required to maintain written
policies, removing the mandated items will allow boards to exercise
their business judgment in developing these policies while remaining
accountable for safe and sound operations.
B. Request for Guidance
Three commenters, while supporting the proposed rule, also
expressed concern about the resulting increased reliance on
institutional interpretation and supervisory judgment. The commenters
wrote that additional clarity would be beneficial to ensure
expectations remain consistent and that FCUs are not subject to varying
interpretations of appropriate governance practices. The commenters
suggested that NCUA clarify, possibly through guidance, that the
rulemaking is not intended to reduce supervisory expectations regarding
due diligence, risk management, underwriting discipline, or board
oversight. The commenters wrote that such guidance would help ensure
continued FCU alignment with safe and sound practices.
NCUA Response. The Board emphasizes that nothing in the final rule
alters the supervisory expectation that FCUs be operated in a safe,
sound, and resilient manner. The final rule removes the overly
prescriptive list of items that must be addressed in an FCU's written
policies regarding the purchase, sale, or pledge of eligible
obligations. However, FCUs are still required to maintain internal
written policies regarding such transactions and will continue to be
evaluated on their compliance with the policies. With regards to the
removal of the conflict of interest provisions, the Board reiterates
that FCUs remain subject to the conflict of interest provisions in
their bylaws and the fiduciary duties of their officials.
C. Additional Deregulatory Suggestions
One commenter, a nonprofit advocacy organization for small credit
unions, supported the proposed rule and urged NCUA to apply the same
principles-based philosophy to address four additional issues.
Specifically, the commenter requested that NCUA: (1) reduce the
frequency and scope of examinations for FCUs with less than $500
million in assets and a CAMELS rating of 1 or 2; (2) ease examiner
``over-compliance'' pressure and acceptance of simple in-house methods;
(3) raise asset thresholds or simplify current expected credit loss
(CECL) accounting methodology and asset liability management/net
economic value requirements; and (4) modernize Bank Secrecy Act (BSA)
rules to reduce pressure on minor, low-impact findings. The commenter
wrote that these are the issues small credit unions have identified as
the most significant in the surveys it has conducted.
NCUA Response. The Board appreciates the feedback provided by the
commenter but notes that the suggestions are outside the scope of this
rulemaking. With regards to the commenter's suggestions regarding
examinations, the Board will continue to assess its examination program
for possible improvements. With respect to the suggestion regarding
BSA, the Board notes that on April 10, 2026, NCUA, the Office of the
Comptroller of the Currency, and the Federal Deposit Insurance
Corporation published a proposed rule to align each agency's anti-money
laundering and countering the financing of terrorism (AML/CFT)
regulations with changes concurrently proposed by the Department of the
Treasury's Financial Crimes Enforcement Network (FinCEN).\5\ The
regulatory amendments are intended to modernize and reform federal
supervision of AML/CFT programs, and to ultimately reduce compliance
burden.\6\ With regards to CECL, the Board notes that the accounting
methodology is mandated under Generally Accepted Accounting Principles.
However, the Board's regulations provide several mechanisms to
ameliorate the effects of CECL on credit unions. Specifically, the CECL
final rule established a three-year phase-in of the adverse effects on
the regulatory capital of credit unions, and exempted credit unions
with total assets of less than $10 million from CECL.\7\
---------------------------------------------------------------------------
\5\ 91 FR 18304 (April 10, 2026); 91 FR 18704 (April 10, 2026).
\6\ See, <a href="https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs">https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs</a>;
<a href="https://ncua.gov/newsroom/press-release/2026/agencies-request-comment-anti-money-laundering-countering-financing-terrorism-proposed-rule">https://ncua.gov/newsroom/press-release/2026/agencies-request-comment-anti-money-laundering-countering-financing-terrorism-proposed-rule</a>.
\7\ 86 FR 34924 (July 1, 2021).
---------------------------------------------------------------------------
D. Opposition to Proposed Rule
Two duplicate comments opposed the proposed rule on general
grounds. The commenters wrote that the current regulations establish
clear standards and are necessary to ensure FCUs are held accountable
for their practices. The commenters did not, however, discuss any of
the details of the proposed rule or this regulation as a whole.
NCUA Response. The Board respectfully disagrees with the comments.
The Board continues to believe that the final rule will relieve FCUs
from the burden of having to comply with an unnecessarily prescriptive
requirement. The regulatory change establishes a principles-based
approach that enables boards to exercise their business judgment, while
preserving the safety and soundness of FCU operations.
E. General Opposition to NCUA's Deregulation Project
One commenter expressed general opposition to NCUA's deregulation
project. The commenter was concerned that NCUA's proposals appear to
prioritize reducing regulatory obligations over maintaining the
safeguards necessary to protect credit unions, preserve institutional
stability, and maintain public trust in the federally insured credit
union system. The commenter wrote that, while several of the proposals
characterize existing regulatory provisions as unnecessarily
duplicative, this duplication may be necessary to ensure clarity and
compliance.
NCUA Response. The Board respectfully disagrees with the commenter.
This final rule is part of NCUA's Deregulation Project, through which
the Board is reviewing all of its
[[Page 50682]]
existing regulations to ensure they are focused on the safety,
soundness, or resilience of credit unions.\8\ The regulations proposed
for removal are those the Board has determined are obsolete, merely
repeat statutory requirements, prescribe guidance rather than
requirements, or are unduly burdensome. The Board disagrees that
duplication may be necessary to ensure the clarity of regulatory
requirements. While regulations are necessary to establish binding
requirements, there are other available resources (such as written
guidance and webinars) that can help address questions regarding the
clarity or scope of specific regulations.
---------------------------------------------------------------------------
\8\ For more information regarding NCUA's Deregulation Project,
please refer to <a href="https://ncua.gov/news/deregulation-project">https://ncua.gov/news/deregulation-project</a>.
---------------------------------------------------------------------------
III. Regulatory Procedures
A. Executive Orders 12866, 13563, and 14192
Pursuant to Executive Order 12866 (``Regulatory Planning and
Review''), a determination must be made whether a regulatory action is
significant and therefore subject to review by the Office of
Information and Regulatory Affairs (OIRA), within the Office of
Management and Budget (OMB) in accordance with the requirements of the
Executive Order.\9\ Executive Order 13563 (``Improving Regulation and
Regulatory Review'') supplements and reaffirms the principles,
structures, and definitions governing contemporary regulatory review
established in Executive Order 12866.\10\ This final rule was drafted
and reviewed in accordance with Executive Order 12866 and Executive
Order 13563. OIRA has determined that this final rule is not a
``significant regulatory action'' as defined by section 3(f) of
Executive Order 12866.
---------------------------------------------------------------------------
\9\ 58 FR 51735 (Oct. 4, 1993).
\10\ 76 FR 3821 (Jan. 21, 2011).
---------------------------------------------------------------------------
Executive Order 14192 (``Unleashing Prosperity Through
Deregulation'') requires that any new incremental costs associated with
new regulations shall, to the extent permitted by law, be offset by the
elimination of existing costs associated with at least 10 prior
regulations.\11\ This final rule is considered an Executive Order 14192
deregulatory action.
---------------------------------------------------------------------------
\11\ 90 FR 9065 (Feb. 6, 2025).
---------------------------------------------------------------------------
B. Regulatory Flexibility Act
The Regulatory Flexibility Act (RFA) \12\ generally requires that,
in connection with a final rulemaking, an agency prepare a regulatory
flexibility analysis that describes the impact of the final rule on
small entities. A regulatory flexibility analysis is not required,
however, if the agency certifies that the rule will not have a
significant economic impact on a substantial number of small entities
(defined for purposes of the RFA to include credit unions with assets
less than $100 million) \13\ and publishes its certification and a
short, explanatory statement in the Federal Register together with the
rule.
---------------------------------------------------------------------------
\12\ 5 U.S.C. 601 et seq.
\13\ See 80 FR 57512 (Sept. 24, 2015).
---------------------------------------------------------------------------
This final rule removes the prescriptive lists of items that must
be addressed in an FCU's written policies regarding the sale, purchase,
and pledge of eligible obligations. While the current requirement to
maintain written policies might impose some economic costs on FCUs,
they are unlikely significant. Although FCUs will still be required to
maintain these written policies, they will no longer be subject to any
additional costs they may have incurred in addressing the items
currently specified in the regulations. Given that the economic costs
of maintaining the current written policies is insignificant, the
economic impact of removing the prescribed lists is equally unlikely to
have a significant economic impact.
The final rule also removes detailed requirements regarding
conflicts of interest and compensation. The permissibility of incentive
structures currently prohibited under the current regulations may have
some economic impact. However, the Board does not anticipate that such
impacts will be significant because FCUs will remain governed by
broader conflict of interest provisions in their bylaws and by the
fiduciary duties of their officials.
Accordingly, NCUA certifies the final rule will not have a
significant economic impact on a substantial number of small credit
unions.
C. Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (PRA) generally provides that
an agency may not conduct or sponsor, and not withstanding any other
provision of law, a person is not required to respond to, a collection
of information, unless it displays a currently valid Office of
Management and Budget control number. The PRA applies to rulemakings in
which an agency creates a new or amends existing information collection
requirements. For purposes of the PRA, an information-collection
requirement may take the form of a reporting, recordkeeping, or a
third-party disclosure requirement. The information collection
requirements contained in Sec. 701.23 are approved by OMB under OMB
control number 3133-0127.
The final rule contains information collection recordkeeping and
reporting requirements that will require revision of an existing
information collection for approval under the PRA. NCUA is proposing to
extend for three years, with revision, its information collection. The
revision was submitted to OMB for approval under OMB control number
3133-0127. The rescission of these regulations, along with the
information collection requirement(s) contained therein and the
revision of OMB control number 3133-0127, will reduce public
information collection burden by an estimated 686 annual burden hours.
Title of Information Collection: Purchase, Sale, and Pledge of
Eligible Obligations, 12 CFR 701.23.
OMB Control Number: 3133-0127.
Estimated Number of Respondents: 343.
Estimated Number of Responses per Respondent: Varies.
Estimated Annual Responses: 343.
Estimated Hours per response: Varies.
Estimated Total Annual Burden Hours: 10,231.5.
NCUA estimates a total annual burden of 10,231.5 hours as follows:
NCUA Summary of Estimated Annual Burden
----------------------------------------------------------------------------------------------------------------
Estimated
Information Number of Responses Hours per annual
12 CFR collection Type of burden respondents per response burden
activity respondent hours
----------------------------------------------------------------------------------------------------------------
701.23(b)(1)................. Develop written Recordkeeping.. 343 1 6 2,058
policies to
purchase,
sell, or
pledge
eligible
obligations.
[[Page 50683]]
701.23(b)(3)(ii)............. Retain a Recordkeeping.. 343 36 0.25 3,087
written
agreement and
schedule of
eligible
obligations
purchased in
the
purchaser's
office, when
purchasing
eligible
obligations.
701.23(b)(3)(iii)............ Request written Reporting...... 35 1 8 280
approval
before
purchasing
eligible
obligations of
a liquidating
credit union.
701.23(b)(6)................. Internal Recordkeeping.. 343 1 4 1,372
written
purchase
policies.
701.23(c)(2)................. Retain a Recordkeeping.. 144 43 0.25 1,548
written
agreement and
schedule of
eligible
obligations
sold in the
seller's
officer, when
selling
eligible
obligations.
701.23(d)(1)(ii)............. Retain copies Recordkeeping.. 343 11 0.25 943.25
of the
original loan
documents when
pledging
eligible
obligations.
701.23(d)(1)(iii)............ Retain a Recordkeeping.. 343 11 0.25 943.25
written
agreement and
schedule of
eligible
obligations
pledged in the
credit union's
office, when
pledging
eligible
obligations.
701.23(g)(1)................. Submit a Reporting...... 0 1 8 0
written
request to
NCUA seeking
expanded
authority
related to the
purchase of
eligible
obligations
from another
federally
insured credit
union.
701.23(g)(1)................. Submit an Reporting...... 0 1 20 0
appeal to the
NCUA Board
regarding a
regional
director's
determination
of the
expanded
authority
request.
----------------------------------------------------------------------------------
Total Estimated Annual ............... ............... ........... .......... .......... 10,231.5
Burden (Hours).
----------------------------------------------------------------------------------------------------------------
D. Executive Order 13132 on Federalism
Executive Order 13132 encourages certain regulatory agencies to
consider the impact of their actions on state and local interests.
NCUA, an agency as defined in 44 U.S.C. 3502(5), complies with the
executive order to adhere to fundamental federalism principles. This
final rule applies solely to FCUs and therefore will not have a
substantial direct effect on the states, the relationship between the
national government and the states, or on the distribution of power and
responsibilities among the various levels of government.
E. Assessment of Federal Regulations and Policies on Families
NCUA has determined that this final rule will not affect family
well-being within the meaning of section 654 of the Treasury and
General Government Appropriations Act, 1999.\14\ The regulatory
requirements that are the subject of this final rule are exclusively
concerned with FCU policies regarding the sale, purchase, and pledge of
eligible obligations. The potential positive effect on family well-
being, including financial well-being is, at most, indirect.
---------------------------------------------------------------------------
\14\ Public Law 105-277, 112 Stat. 2681 (1998).
---------------------------------------------------------------------------
F. Congressional Review Act
Subtitle E of the Small Business Regulatory Enforcement Fairness
Act of 1996, also known as the Congressional Review Act (CRA),
generally provides for congressional review of agency rules.\15\ NCUA
must submit a report to Congress and the Comptroller General when it
issues a final rule, as defined by the CRA.\16\ An agency rule, in
addition to being subject to congressional oversight, may also be
subject to a delayed effective date if the rule is a ``major rule.''
OIRA has determined that this rule is not a ``major rule'' within the
meaning of the relevant sections of the CRA. NCUA will also file
appropriate reports with Congress and the Comptroller General so this
rule may be reviewed.
---------------------------------------------------------------------------
\15\ 5 U.S.C. 801-808.
\16\ 5 U.S.C. 804(3).
---------------------------------------------------------------------------
List of Subjects
12 CFR Part 701
Advertising, Aged, Civil rights, Credit, Credit unions, Fair
housing, Individuals with disabilities, Insurance, Marital status
discrimination, Mortgages, Religious discrimination, Reporting and
recordkeeping requirements, Sex
[[Page 50684]]
discrimination, Signs and symbols, Surety bonds.
12 CFR Part 746
Administrative practice and procedure, Claims, Credit unions,
Investigations.
By the National Credit Union Administration Board, this 29th day
of July, 2026.
Melane Conyers-Ausbrooks,
Secretary of the Board.
For the reasons stated in the preamble, the NCUA Board amends 12
CFR parts 701 and 746, as follows:
PART 701--ORGANIZATION AND OPERATION OF FEDERAL CREDIT UNIONS.
0
1. The authority citation for part 701 continues to read as follows:
Authority: 12 U.S.C. 1752(5), 1755, 1756, 1757, 1758, 1759,
1761, 1761a, 1761b, 1766, 1767, 1782, 1784, 1785, 1786, 1787, 1788,
1789. Section 701.6 is also authorized by 15 U.S.C. 3717. Section
701.31 is also authorized by 15 U.S.C. 1601 et seq.; 42 U.S.C. 1981
and 3601-3610. Section 701.35 is also authorized by 12 U.S.C. 4311-
4312.
Sec. 701.23 [Amended]
0
2. Amend Sec. 701.23 by:
0
a. Revising paragraphs (b)(6), (c), and (d)(1);
0
b. Removing paragraph (g); and
0
c. Redesignating paragraph (h) as paragraph (g), to read as follows:
Sec. 701.23 Purchase, sale, and pledge of eligible obligations.
* * * * *
(b) * * *
(6) Written purchase policies. Purchases of eligible obligations
and notes of liquidating credit unions must comply with the purchasing
Federal credit union's internal written purchase policies.
(c) Sale. A Federal credit union may sell, in whole or in part, to
any source, eligible obligations of its members, eligible obligations
purchased in accordance with paragraph (b)(1)(ii) of this section,
student loans purchased in accordance with paragraph (b)(1)(iii) of
this section, and real estate loans purchased in accordance with
paragraph (b)(1)(iv) of this section, within the limitations of the
board of directors' written sale policies.
(d) Pledge. (1) A Federal credit union may pledge, in whole or in
part, to any source, eligible obligations of its members, eligible
obligations purchased in accordance with paragraph (b)(1)(ii) of this
section, student loans purchased in accordance with paragraph
(b)(1)(iii) of this section, and real estate loans purchased in
accordance with paragraph (b)(1)(iv) of this section, within the
limitations of the board of directors' written pledge policies.
* * * * *
PART 746--APPEALS PROCEDURES
0
3. The authority citation for part 746 continues to read as follows:
Authority: 12 U.S.C. 1766, 1787, and 1789.
Sec. 746.201 [Amended]
0
4. In Sec. 746.201, revise the reference to ``701.23(h)(3)'' to read
``701.23(g)(3).''
[FR Doc. 2026-16030 Filed 8-5-26; 8:45 am]
BILLING CODE 7535-01-P
</pre></body>
</html>Indexed from Federal Register on August 6, 2026.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.