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FOM Proposal Comments Wanted ASAP
Friday, December 11, 2015 6:50 AM

Credit unions have 60 days to let the National Credit Union Administration know how they feel about the new field of membership (FOM) proposal. The proposal has been published in the Federal Register, which opens up the comment period. Credit unions have until Feb. 8, 2016, to submit formal comment letters to the NCUA.

These letters should reflect credit unions' official position on the FOM proposal. For these formal comment letters, we urge credit unions to submit comment letters directly to NCUA using the instruction in the proposed rule or to submit comments through PowerComment, which will email the comment letter directly to the NCUA.

We encourage credit union employees to use the Voter Voice system to submit pre-written comment letters. As always, users who would like to edit or add additional comments to the pre-written letters are able to do so. This is the fastest way to send a comment to the NCUA. CUNA's goal is to have 7,500 of these pre-written letters sent to the NCUA.

Please don't forget to send a copy of your comment letters to Cornerstone SVP Regulatory Compliance Suzanne Yashewski at

“Bankers are already commenting in an effort to stifle credit union growth," Yashewski says. "It is imperative that credit unions submit comment letters in large numbers; we cannot let the bankers control our future.” 

The banks and their grassroots teams are using similar systems to comment against the Field of Membership proposal.

The NCUA has a comparison chart for the old and new rule that will also help credit unions better understand the changes.