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Comment Letters Urgently Needed; Field of Membership Proposal Deadline June 30
Tuesday, June 24, 2014 6:35 AM

The June 30 deadline for submitting your comment letters for NCUA's field of membership proposal is fast approaching. So far, only five letters have been submitted to NCUA, including a letter from the American Bankers Association, which not only supports the proposal but advocates even stricter requirements.

Don't let bankers shape our field of membership rule! Write your comment letter today on this important issue, and please let the compliance group at Cornerstone Credit Union League help you, if needed.

The agency is proposing several amendments to the associational field of membership requirements for federal credit unions, making it more difficult to expand their membership. NCUA has also suggested that it intends to scrutinize associations currently included in your field of membership.

The proposal would do three main things:

  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.

To read more about this proposal and what you can do to help prevent more stringent rules on your field of membership, go to Cornerstone's Compliance Comment Calls page.

If you have questions, please contact Suzanne Yashewski at (512) 853-8515, or syashewski@cornerstoneleague.coop. It is vital that we hear your concerns so we can best represent member credit unions on regulatory matters.

NOTE:  We track comments, so if you've already written your comment letter, please be sure to get your participation on the record! Send a copy to Suzanne Yashewski at syashewski@cornerstoneleague.coop.