Removing Barriers Blog

Field of Membership Proposal Expected to be Released Thursday
Posted November 16, 2015 by CUNA Advocacy

This week, we expect NCUA to propose a new field of membership regulation that incorporates several of the recommendations we proposed earlier this year.

As part of our ongoing and comprehensive effort to improve the operating environment for credit unions to serve their members, we encouraged NCUA to adopt new field of membership regulations that recognize and adapt to the changes have taken place in the marketplace and in how credit unions serve members.  We encouraged the agency to take immediate administrative action in areas that did not require a change in regulation, to propose new regulations to expand consumer and small business access to credit unions, and to support statutory changes that go beyond what is presently permitted by law.

The first fruit of this effort took place last month when NCUA shaved at least two months off the amount of time necessary to expand a community charter by delegating approval authority to the Office of Consumer Protection.  Previously these approvals required a full vote of NCUA's board.  Now, we’re excited to see a new regulatory proposal.

Here are some things CUNA recommended that we are keeping out eye out for.  We encouraged NCUA to:
  • include a combined statistical area in the definition of well-defined local community.
  • Allow a Congressional district to be considered a well-defined local community (this would allow credit unions to serve an entire state in a state that has only one Congressional district).
  • Eliminate the population test associated with the definition of “rural district.”
  • Reinstate a narrative approach for defining a community.
  • Eliminate the geographic limitations on TIP charters.
  • Allow TIP charters to serve independent contractors and others who support the work of the TIP.
  • Allow groups with 3,000 or more potential members to more easily be added to multi-group federal credit unions. 
The proposal will be released on Thursday.  We will have an immediate reaction to the proposal on the Removing Barriers Blog and in New Now, followed by a more detailed analysis next week.