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NCUA to Consider FOM Rules Nov. 19 at Livestreamed Meeting
Thursday, November 12, 2015 6:40 AM

A field of membership (FOM) proposed rule will be taken up at the National Credit Union Administration’s Nov. 19 meeting, as requested by Credit Union National Association. FOM reform is a top issue for CUNA, and CUNA has urged the agency to refrain from imposing any FOM restrictions beyond what is required in the Federal Credit Union Act.

The meeting will begin at 9 a.m. (Central Time) Nov. 19, and will be streamed live on the NCUA’s website. 

In a letter sent to the NCUA in June, CUNA outlined a number of principles for FOM reform, as well as a number of suggestions that are within the agency’s immediate authority and some that would require a rule change. Specific changes CUNA has requested include:

  • Allow any federal credit union to serve a combination of contiguous communities and single political jurisdictions that do not exceed in population size or land area of the largest community that NCUA has already approved which means 10 million people or a land area of 20,000 square miles;
  • Allow any government definition of community to be used as a credit union’s option to define Well-Defined Local Community (WDLC);
  • Increase the population limit used for Core Based Statistical Areas (CBSA) from 2.5 million to 10 million;
  • Eliminate the requirement that a CBSA contain a “core”; 
  • Include Combined Statistical Area in the definition of WDLC; 
  • Expand affinity groups for community chartered credit unions beyond those who live in, worship in, attend school in or work in a community. This should be expanded to include those who work for a business headquartered or are paid from a business located in a community; 
  • Redefine “rural district” by eliminating a population test and using a test similar to that of the U.S. Census Bureau as an area that does not contain a majority of land area in an Urbanized Area or Urbanized Cluster;
  • Allow a Congressional district to be considered a WDLC. A Congressional district inherently defines a community with shared interests;
  • Reinstate the narrative approach for defining a community;
  • Eliminate the geographic limitation on trade, industry or profession (TIP) for federal credit unions;
  • Allow a TIP to add vendors and their employees that support the trade, industry or profession;
  • Allow a professional-based TIP to include co-workers who support the professional’s day-to-day delivery of services and to include recipients of the professional’s services when those recipients are not customers or clients;
  • Streamline the paperwork and process to allow groups with 3,000 or more potential members to easily be added to a multiple group federal credit union;
  • Permit federal credit unions that convert to a community charter to keep approved groups in their FOMs that are outside the boundaries of their new community; and
  • Permit a state credit union converting to a federal credit union to keep its current field of membership and expand based on NCUA’s field of membership policies.