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Debt Obligations of the National Credit Union Administration

Date of Issuance:

Debt obligations of the National Credit Union Administration, lawfully incurred on behalf of the Central Liquidity Facility, pursuant to 12 U.S.C. § 1795f(a), represent obligations of the United States backed by its full faith and credit.

There is a presumption, historically reflected in opinions of the Attorney General, that federal agency obligations are supported by the full faith and credit of the United States, unless the statute authorizing such obligations expressly provides otherwise. This presumption extends to obligations incurred by an agency on behalf of a non-federal entity.

While principles of restraint and respect for the Comptroller General as an agent of Congress ordinarily require that his opinions be accorded substantial weight by the Attorney General, in this case the Comptroller General failed properly to apply the legal principles governing full faith and credit which are delineated in the opinions of the Attorney General.

Opinions of the Attorney General on matters of law are, as a matter of course, to be followed by all officers of the Executive Branch.

Updated July 9, 2014