National Credit Union Administration

Office of Credit Union Resources and Expansion

February 22, 2021

SENT BY EMAIL: admin@worldcreditunion.org

Hon. Larry Shelton

411 West Rd Apt 811
Houston, TX 77038

RE: Chartering Proof of Concept Application

Proposed World Temple Federal Credit Union

Dear Hon. Shelton:

This letter is in response to the Chartering Proof of Concept Application submitted by your
organizing group on December 17, 2020. Our attempts to meet with you on December 29 and
December 30, 2020 were unsuccessful. We therefore ask that you address the items below by
resubmitting your POC application at your earliest convenience.

The NCUA’s Office of Credit Union Resources and Expansion (CURE) uses a scoring model to
evaluate the Chartering Proof of Concept submission. Each of the four critical elements has a
value of 25 points for a total of 100 potential points. An organizing group’s submission must
achieve at least 80 points to be considered favorable.

CURE has completed its review of your Chartering Proof of Concept submission, which received
an unfavorable rating with a total score of 64 points. The unfavorable rating means your group
did not provide enough information to support its ability to form a credit union.

In particular, your group did not provide sufficient information to assess whether your purpose
and core values align with the framework of a federal credit union; whether the proposed field of
membership (FOM) meets the common bond requirements; and did not provide adequate
documentation supporting sufficient start-up capital to form a new federal credit union. Below
are specific comments on the purpose and core values, field of membership, and capital sections
of the POC that have unsupportable answers or insufficient detail.

Critical Element #1 – Purpose and Core Values

The information provided within this section does not communicate how the purpose and values
of the proposed World Credit Union align with a credit union chartered by the National Credit
Union Administration (NCUA). Notably, the information provided within the submission
suggests that the credit union will serve a global community’s financial trading, digital currency
exchange, and other complex financial needs in an effort to promote self-sufficiency and
sustainability in local communities through individual community exchanges utilizing “The
WORLD OPEN MARKETS CES.”

Critical Element #2 – Field of Membership

The group has not specifically defined a field of membership that conforms with the NCUA
Rules and Regulations Part 701 Appendix B. The submission indicates the desire for a

1775 Duke Street – Alexandria, VA 22314-6113 – 703-518-(Insert

Main Office No.)
Hon. Larry Shelton
February 22, 2021
Page 2

community charter field of membership but does not identify any specific political jurisdictions
or rural districts for inclusion within the FOM.

The submission estimates 4,000 potential members and supports this estimate through the
assumption that the credit union will have access to billions of members through bitcoin block
chain. It is not clear, however, how the members of the bitcoin block chain community can meet
the requirements for membership established by the NCUA.

Critical Element #3 – Capital

The submission states that the World Government/World Temple has pledged $100,000,000 in
capital donations. While the amount of funding pledged is likely sufficient to start a credit
union, the amount itself is not fully supported within the submission. Notably, the proof of
concept submission quotes the World Government/World Temple’s monetary value in various
currencies that are not officially recognized by the United States Government. As such, the
submission would need substantial documentation to support the pledge of $100,000,000 in
capital donations.

The submission is also unclear on whether or not the $100,000,000 is truly pledged by the World
Government/World Temple to start the proposed credit union. On page three of the proof of
concept submission, a request for financing is made with the comment “If payback of this
financing is required by the lender or lender bank, such repayment will be made in US dollars
only.”

Please provide formal documentation of the commitments for capital funding, stating the capital
funds are donations, not refundable contributions, and identifying the amount and source of
funds from the donor representing the $100,000,000 in total donations identified. Commitment
letters signed by the donor and documentation supporting their sources of the funding will
strengthen this response.

Please clarify how you will operate profitably after the financial support is exhausted. Your
initial response does not provide quantifiable support for the favorable response stated on the
POC submission.

To address the deficiencies in the two critical elements discussed above, please edit your earlier
chartering Proof of Concept submission and provide supporting documentation as requested.
The NCUA will review your updated submission and provide a letter with instructions on the
next steps to move forward in the chartering process.
Hon. Larry Shelton
February 22, 2021
Page 3

We appreciate your interest in forming a new federal credit union. If you have questions, please
contact Consumer Access Coordinator Sam Stahlmann by email at sstahlmann@ncua.gov or by
telephone at (703) 624-8675.

Sincerely,
Digitally signed by
JOHN JOHN TAMASHIRO

TAMASHIRO Date: 2021.02.22

16:39:52 -05'00'

John Tamashiro
Director, Division of Consumer Access

CURE/SDS:SDS
SSIC 6400

cc: Sam Stahlmann, Consumer Access Coordinator, NCUA