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Cornerstone Supports NCUA's New FOM Proposal in Comment Letter
Wednesday, December 7, 2016 6:55 AM

Cornerstone Credit Union League has sent their comment letter to the National Credit Union Administration for its proposal regarding field of membership (FOM) rules in relation to community charters. The proposal would efforts to ease outdated field of membership restrictions.

"We support amending the chartering and field of membership rules to give applicants for community charter approval, expansion, or conversion the option, in lieu of a presumptive community, to submit a narrative to establish common interests or interaction among residents of the area it proposes to serve, thus qualifying the area as a well-defined local community," wrote Cornerstone SVP Regulatory Compliance Suzanne Yashewski. "We support the suggested criteria to be used in evaluating the presence of interaction and/or common interest among residents in these areas. Such an approach provides flexibility to credit unions seeking to best serve their communities."

Yashewski said that Cornerstone also supports NCUA's proposal to increase population limit to 10 million on a community consisting of a statistical area or a portion thereof. "This approach anticipates population growth over time, and also provides some parity with state-chartered credit unions in many states that permit a statewide FOM," she wrote.

Cornerstone also supports permitting a credit union to designate a portion of an area as its community without regard to division boundaries when such an area is subdivided into metropolitan divisions. Yashewski wrote, "The proposed amendment fixes inconsistencies in the treatment of a portion of a core based statistical area versus that of a combined statistical area."

All credit unions are requested to send in their comments about this proposal by the deadline date of Friday, Dec. 9. Need help? Visit our compliance site here.

View Cornerstone's comment letter in the Compliance > Comment Letters section of the website. Both links will require your Cornerstone CUpassport ID and password.

If you need help in crafting comment letters, or if you have questions about this proposal, please contact Suzanne Yashewski at or 512-853-8516.