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Call to Action: NCUA Needs to Hear from You
Monday, June 9, 2014 6:40 AM

Is your credit union federally chartered with single common bond or multiple common bond field of membership?  If so, your current field of membership, and your ability to grow in the future, is under attack by the National Credit Union Administration. 

NCUA is proposing several amendments to the associational field of membership [“FOM’] requirements, making it more difficult for credit unions to expand membership.  NCUA has also suggested that it intends to scrutinize associations currently included in your FOM.  The proposal would do three main tings:

  1. Establish a threshold requirement that an association not be formed primarily for the purpose of expanding credit union membership;
  2. Add an additional element to the “totality of circumstances test” which would include evaluating corporate separateness between the credit union and any association; and,
  3. Grant automatic qualification to certain categories of associations.

The NCUA is taking a stricter approach to compliance with the FOM legal requirements.  NCUA alleges that some credit unions have attempted to expand their potential FOM beyond appropriate limits.  Additionally, some credit unions have advertised that membership is “open to anyone,” and NCUA believes this to be misleading and inaccurate advertising. By further scrutinizing the kinds of associations that are included in a field of membership, both existing and new, the NCUA feels it can ensure compliance with FOM requirements.

The proposed rules are likely to impact some groups that, while providing membership to the credit union as a possible benefit, also provide other valuable services.  In addition, the ability of credit unions to continue an indirect lending program through an expansion-focused association might be seriously hampered by this proposal.

Below are some suggested talking points; you may pick and choose issues on which to comment:

  • Support NCUA’s effort to grant automatic qualification for certain groups. Comment on additional groups that should be granted automatic acceptance.
  • If you have concerns with the requirements regarding associational bonds, oppose that portion of the proposal.
    • Address the importance of preserving existing associations and request that those be grandfathered.
    • If the additional new “corporate separateness” element will cause problems, discuss how.
    • Voice concern that the immediate disqualification of certain potential associations would impact your credit union’s ability to legitimately expand.
    • Discuss how the restriction on certain kinds of associations might impact indirect lending relationships.


HOW TO SUBMIT COMMENTS:                             

You may submit comments in any of the following ways:

Email: Address to

Include the following in the subject line: “[Your Name] Comments on Associational Common Bond and Field of Membership Proposal”

Mail: Address to Gerard Poliquin, Secretary of the Board, National Credit Union

Administration, 1775 Duke Street, Alexandria VA 22314-3428.

Fax: (703) 518-6319


Please submit your comments as soon as possible, but no later than June 30th, 2014.

To view already submitted comments, click here.


Please don’t forget to share your comments with Cornerstone by emailing them to Suzanne Yashewski at It is vital that we hear your concerns so we can best represent member credit unions on regulatory matters.

We track comments, so be sure to get your participation on the record!

If you have any questions, please contact Cornerstone Credit Union League Senior Vice President of Regulatory Compliance Counsel Suzanne Yashewski at or (512) 853-8516.

Cornerstone urges credit unions not to feel intimidated by the comment process. Your comment letter can be short and to-the-point. A formal business letter is great, but a short and simple email works too; you don’t have to hit every talking point. Just be sure to let NCUA know who you are and how this proposal would impact the credit union and its members.

Don’t be silent on such a key issue. Write your comment letter today!