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CUNA Supports FOM Proposal and NCUA Providing Further Relief
Thursday, February 4, 2016 6:45 AM

The Credit Union National Association fully supports the proposed field-of-membership modifications from the National Credit Union Administration, but believes the agency can go even further under its legal authority to provide regulatory relief. CUNA filed its comment letter on the proposal today, ahead of the Feb. 8 deadline.

“CUNA strongly supports this modernization effort and encourages the NCUA board to quickly adopt all of the proposed changes along with our additional suggestions, which will make NCUA’s proposal even more robust,” the letter reads. “We applaud NCUA for recognizing the stagnant nature of the agency’s FOM requirements when compared to some innovative state charters.”

The changes are needed because credit unions and CUNA are concerned that the federal charter is falling behind many state charters; thus, it has become a barrier to the flexibility needed to operate dynamic and efficient cooperative financial institutions.

Those additional improvements include:

  • Improving the merger process by having the NCUA facilitate mergers between credit unions with unlike field of membership when there is no desire to retain the merged credit union’s field of membership by establishing a process that eliminates the need for a conversion. NCUA could do this by providing clear guidance;
  • Allowing federal credit unions that convert to a community charter to keep approved groups in their fields of membership that are outside this new community;
  • Addressing expansion by credit unions with grandfathered field of membership that do not fit under current or proposed rules;
  • Re-instating the pre-2010 narrative approach for defining a community to be used when a community cannot be adequately defined by a statistical area or political jurisdiction;
  • Further evaluation of the agency’s process for approving field of membership expansion. CUNA receives a number of complaints about the onerous expansion application process;
  • Increasing efforts by the NCUA to help credit unions find and serve underserved areas. This includes approving underserved areas that are contiguous with a boundary, eliminate or raise the population limit for statistical areas and develop a list of underserved areas and make that list available to credit unions.

Regarding the provisions already in the proposal, CUNA makes a number of suggestions including raising the rural district population limit to one million people (while grandfathering higher limits allowed under the current rule); raising the threshold to 5,000 employees working at a facility or industrial park to fall in a field of membership (the NCUA proposed a 3,000 limit); and raising the threshold of people in stand-alone groups that can form a new credit union to 10,000.

Cornerstone encourages all credit unions to do one or both of the following:

  • Send a form letter email to NCUA and their members of Congress through Voter Voice. This is the form letter sent for the purpose of increasing numbers. The form letter is a quick and easy way to make a numbers impact. Multiple employee letters from the same credit union are allowed and encouraged.
  • Send your unique letter from the CEO to make an even bigger impact. Credit unions are encouraged to use PowerComment to file comment letters with regulators.


Please refer to Cornerstone's Regulatory Grid Summary or CUNA's Comment Calls page for more details about this proposal and writing your comment letter. Don't forget to copy Suzanne Yashewski so the league can track participation.

If you need help crafting your own letters, or if you have questions, please contact Cornerstone Credit Union League SVP Regulatory Compliance Suzanne Yashewski at syashewski@cornerstoneleague.coop or 512-853-8516.