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Dec. 9 Comment Deadline on FOM Amendments Fast Approaches
Monday, December 5, 2016 6:50 AM

Comments on the NCUA’s field-of-membership proposal, which includes several CUNA-suggested changes to the final rule adopted by the board in October, are due Dec. 9, Cornerstone and CUNA remind credit unions.

The NCUA plan proposes to increases to 10 million the current 2.5 million population limit that applies to a community consisting of a Core Based Statistical Area (CBSA) or Combined Statistical Area (CSA) subject to a credit union’s ability and commitment to adequately serve the area.

In its Federal Register document, the NCUA explains that the higher cap better anticipates and accommodates “inevitable growth” to the extent permissible by law.

The amendments also would allow a return to submitting a narrative to establish common interests or interaction among residents of the area a credit union proposes to serve, thus qualifying it as a well-defined local community, rather than relying on a “presumptive community.”

Finally, it also corrects an error in the final rule that inadvertently restricted fields of membership inside CSBAs to not more than 2.5 million people in a metropolitan division, rather than in the CSBA.

Suzanne Yashewski, Cornerstone SVP regulatory compliance counsel, urges credit unions to submit a comment letter in support of the proposed rule. “Bankers have been writing letters in opposition of FOM growth. It is important that credit unions, particularly community credit unions, weigh in supporting the proposal.” 

Comments can be emailed to NCUA at Please copy Yashewski at