NCUA OK’s Revised Field of Membership Rule & Issues Second Proposal
October 27, 2016
October 27, 2016
The National Credit Union Administration Board voted yesterday to finalize its field-of-membership (FOM) rule. John Trull, AVP of Regulatory Advocacy was encouraged following the meeting.
“This was a thoughtful, pragmatic process by the NCUA, in producing a rule consistent with the law and utilizing the comment process effectively to bring together stakeholders,” Trull said.
“The NCUA has fulfilled an obligation to the credit union system to modernize the Field of Membership rules which hadn’t been updated in nearly two decades, since the passage of CUMAA.”
The final rule becomes effective 60 days after being published in the Federal Register and implements policy changes affecting the definition of a local community, a rural district, underserved area, multiple common bond, and single common bond.
A summary of key changes can be found here.
Second proposal issued—action needed soon
In addition, the NCUA proposed a second field of membership rule addressing three issues that were beyond the scope of the Boards 2015 proposal. The new proposal would:
“We will need letters from every credit union in support of the new proposal… Credit unions should expect a Call to Action in early November.”
– John Trull, AVP of Regulatory Advocacy
- Allow credit unions to use the narrative model to make a case to serve the area they would ideally like to serve, and outlines persuasive arguments;
- Allow credit unions to serve a portion of a Core Based Statistical Area;
- Finally, the board is considering expanding the population limit from the just approved 2.5 million, to 10 million.
The new proposal will have a 30 day comment period once it is published in the Federal Register.
“This is an incredible opportunity with a short window,” said Trull “We will need letters from every credit union in support of the new proposal, and substantive arguments, in defense of expanding the population limit.” Credit unions should expect a Call to Action in early November.
Some things to consider include
- Whether, in view of technological advances since CUMAA, such as the Internet, the Board should consider whether, and how, online social communities qualify as a well-defined local community;
- Whether to apply any population limit at all if the area is completely or primarily urban.
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