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Cornerstone Reminds CUs that June 30 is Deadline to Submit Comment Letters for NCUA's Field of Membership Proposal
Friday, June 27, 2014 7:00 AM

The Cornerstone Credit Union League reminds credit unions that June 30 is the deadline to submit comment letters for the National Credit Union Administration’s field of membership proposal. Reportedly, only a handful of letters have been submitted thus far.

The NCUA is proposing several amendments to the associational field of membership 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 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.

Please note that Cornerstone tracks comments, so if you've already written your comment letter, please be sure and send a copy to Suzanne Yashewski, Cornerstone senior vice president of regulatory compliance, at