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CUs Needed! Six Days Remain to Submit FOM Letters to NCUA
Tuesday, February 2, 2016 7:00 AM

Only six days remain until the comment period closes on proposed modernizations of the National Credit Union Administration's field-of-membership (FOM) regulations, which set the rules determining who credit unions can have as members. Cornerstone Credit Union League and the Credit Union National Association strongly support the proposed improvements, along with the NCUA’s efforts to streamline the agency’s FOM processes.

National and state bank trade associations are hot on the heels of the issue, sending hundreds of letters not only to the NCUA, but also to congressional leaders. As a result, Cornerstone and CUNA are shooting for a very large number of form comment letters from credit unions in addition to the more unique letters usually requested.

In a letter to Congress last week, CUNA President/CEO Jim Nussle took the American Bankers Association and Independent Community Bankers Association to task for the “factually incorrect” letters sent to Congress. CUNA’s resources include a detailed summary of the proposal and a comment letter guide to support credit unions as they develop substantive comment letters.

The proposal was issued for comment at the NCUA board’s November meeting and carries a number of changes CUNA advocated for, including:

  • Allowing rural districts to be comprised of up to 1 million residents by changing the standard used to measure it. That is four times greater than the current cap of 250,000;
  • Allowing a congressional district to be considered a "well-defined local community" to support a community charter application;
  • Eliminating a geographic limitation on trade, industry or profession charters for federal credit unions with associational common bond memberships; and
  • Streamlining the paperwork and process to allow credit unions to add groups with up to 5,000 potential members to be added to a multiple common bond federal credit union. The current rule limits these groups to 3,000 potential members.

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 or 512-853-8516.