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CUNA Continues to Seek Comments on NCUA's Field of Membership Proposal
Monday, June 23, 2014 6:30 AM

Credit unions can still provide comments to CUNA and NCUA on the agency’s proposed rulemaking regarding associational common bond requirements. The proposal would affect the process for adding associations and the types of associations that can be added to a credit unions field of membership (FOM).

Cornerstone agrees that there are positives such as automatic approval of several associational groups. However, among other issues credit unions are concerned about, NCUA has added a threshold test, which would allow an application to be disapproved if the "association has been formed primarily for the purpose of expanding credit union membership."

The threshold test also contains a one-year-in-operation requirement, and there are concerns this could make it difficult for an association with ties to a credit union to be approved by NCUA. NCUA has added a separateness factor to its "totality of circumstances" test that the agency uses when analyzing an association that a credit union desires to add to its FOM. Although not necessarily determinative, this factor requires that an association operate separately from a credit union.

Please submit comments to CUNA by Monday, June 23, 2014. NCUA is accepting comments until June 30, 2014.