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NCUA Votes on Revisions to Finalize FOM Rule
Friday, June 22, 2018 6:45 AM

Yesterday, the National Credit Union Administration voted on several revisions at its monthly meeting, namely a final rule on field of membership. The rule will permit credit unions to submit a field of membership application to serve a well-defined local community exceeding 2.5 million people.  

Credit Union National Association and Cornerstone Credit Union League strongly support the NCUA's efforts to modernize field of membership. CUNA has been actively engaged in this issue since sending NCUA a detailed letter outlining changes NCUA could make to modernize field of membership rules.  

“NCUA has once again acted within its statutory authority to modernize field-of-membership regulations, and we strongly support them in these efforts,” said CUNA President/CEO Jim Nussle. “We thank NCUA for continuing its work to ensure consumers have access to not-for-profit, member-owned financial institutions, despite bankers’ efforts to deprive them of that choice.” 

Cornerstone Credit Union League's Suzanne Yashewski, SVP regulatory compliance counsel, noted that “Cornerstone supports the new FOM rule, as well as NCUA’s decision to appeal the recent adverse court ruling on FOM."

The final rule will give credit unions the option to submit a narrative approach application, which the NCUA used prior to 2010, to serve a field of membership exceeding 2.5 million people. Under this new rule, credit unions can submit a narrative to explain the existence of a well-defined local community rather than limiting them to a statistical community.  

For the applicants who request a community that exceeds a population of 2.5 million people, the NCUA will hold a public hearing to address their narrative. And for communities that are subdivided into metropolitan divisions, applicants will be permitted to designate a portion of this area as its community and disregard division boundaries. 

CUNA was also a vocal defendant of the NCUA during a lawsuit filed by the American Bankers Association in December 2016. The appeal challenged their authority to declare the rule and is a clear display of trite attacks against credit unions by banks attempting to limit their access. Following the lawsuit, NCUA proposed a population limit boost to 10 million people 

Expanding the proposed communities would grant more consumers eligibility to join a credit union. CUNA has strongly pushed for the narrative approach in multiple comment letters sent to NCUA on field of membership.  

Learn more about the NCUA board meeting and decisions about FOM, MBL, modernization, and mergers.