Removing Barriers Blog

Comments submitted to NCUA on FOM rulemaking
Posted December 09, 2019 by CUNA Advocacy

CUNA sent comments to the NCUA in response to their Chartering and Field of Membership Proposed Rule, the latest field-of-membership proposal, as it reinstates portions of the 2016 rulemaking that were vacated by a U.S. District Court decision.

The proposal would re-adopt a provision to allow an applicant to designate a Combined Statistical Area (CSA), or an individual, contiguous portion thereof, as a well-defined local community (WDLC), provided that the chosen area has a population of 2.5 million or less.

NCUA also proposed to clarify existing requirements and add an explicit provision to its rules to address concerns about potential discrimination in the FOM selection for CSAs and Core Based Statistical Areas.

CUNA and the Leagues are currently awaiting decision from the D.C. Circuit Court of Appeals on an American Bankers Association motion for an en banc rehearing, with the letter noting how such efforts by the banking trades limit consumers’ financial wellness:

“It’s unfortunate for Americans lacking access to financial services that the ABA and their partners continue to pursue strategies to limit access to credit unions. We fully expect the ABA and the Independent Community Bankers of America (ICBA) to continue pursing litigation strategies aimed at limiting credit unions’ ability to serve their communities. Litigation and other strategies, such as the continued attack on credit unions’ tax status, are nothing more than an attempt to distract from the culprit responsible for the contraction of the community bank sector – the large banks. As underscored by the Federal Reserve Bank of St. Louis this year, for community bankers inspired by a locally-driven mission, credit unions become ideal partners not only because they are strong buyers, but because they are the best institution to carry on that mission to serve.”