Removing Barriers Blog

Update on NCUA Field of Membership Proposal Comment Letters
Posted January 08, 2016 by CUNA Advocacy

As we are getting closer to the comment deadline for NCUA’s Proposed Field of Membership (FOM) rule, we figured it would be a good idea to update folks on the progress so far.  As you know, the comment period on this proposal ends on February 8, 2016.  To date, NCUA’s website reflects in excess of 1100+ letters from credit unions in support of the rule, including letters from Congressmen Brad Sherman (CA) and John Garamendi (CA). 

We have been tracking the comment letters as they’ve come in and identified letters from the following states:  AK, AR, CA, CO, CT, DC, DE, FL, GA, HI, ID, IN, KY, LA, MA, MD, ME, MO, MS, MT, ND, NE, NJ, NM, NV, NY, OH, OK, OR, PA, SD, TN, TX, VA, WA, WI, and WV.  (Please note that there is a several day lag from the time NCUA receives a letter and the time that it is posted.)

This is a great start, but we need to keep up the activity.  While we have not seen significant letter activity from the bankers, we do anticipate them to voice their strong opposition prior to the close of the comment period. 

Please continue to encourage your credit unions to write comment letters on this proposal.  We have a lot of information on our FOM resource page that should help credit union through the proposed rule and to comment to the NCUA, a detailed summary to help parse through the proposed rule to determine how it would impact your credit unions.  We plan on sending additional material to credit unions in the coming days.

Also, we encourage you to reach out of credit union friends in Congress to encourage them to write the NCUA in support of the proposal.  The Sherman and Garamendi letters are great examples of what could be sent.  We’re happy to help draft something for an interested Member of Congress to send.

If you have questions or concerns, please do not hesitate to contact Ryan DonovanElizabeth Eurgubian, Lance Noggle, or Andy Price.