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Cornerstone Urges NCUA to Look for Ways to Expand Field of Membership so CUs can Better Serve Communities
Wednesday, July 2, 2014 7:00 AM

While the Cornerstone Credit Union League supports several provisions of the National Credit Union Administration’s proposed rule, Associational Common Bond and Field of Membership Requirements, Cornerstone Senior Vice President of Regulatory Compliance Suzanne Yashewski is urging the agency to look for ways to expand field of membership so that credit unions can better serve their communities.

“Cornerstone supports the NCUA’s proposal to grandfather in existing associations. We feel that this provision will provide an element of security to our credit unions, and should extend to all current associations,” Yashewski writes in a June 30 letter to Gerard Poliquin, secretary of the NCUA board. “Many of these associations have existed for decades, and the benefit of credit union membership is a known and marketed benefit for these associations. The concept of once a member always a member should be applied to associations within the field of membership. Credit unions and affiliated associations should continue these relationships unfettered by any de novo scrutiny.”

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.

June 30 is the deadline to submit comment letters for the National Credit Union Administration’s field of membership proposal.  

Yashewski tells Poliquin that although Cornerstone appreciates the NCUA’s proposal to protect credit unions by preserving a healthy marketplace for financial services, she asks that the agency exercise caution in how it applies any new standards, such that they do not unduly restrict the ability for credit unions to lawfully expand, or threaten the associations to which credit unions currently offer services. 

To read Yashewski’s letter, please click here. Please note that you will need to enter your username and password in order to view this letter on Cornerstone’s website.