WASHINGTON—CUNA said it is broadly supportive of NCUA’s proposed changes to its chartering and field of membership (FOM) rules, but has also offered a number of suggestions it would also like to see.
In its comment letter to the agency, CUNA said, “While we recognize that NCUA is restricted by provisions of the Federal Credit Union Act (FCUA), we believe there is additional flexibility to update these requirements so they are current with today’s economic and technological environment.”
Among the changes CUNA said it would like to see:
- Merger Process Improvements. NCUA should facilitate mergers between credit unions with unlike fields of membership when there is no desire to retain the merged credit union’s field of membership by establishing a process that eliminates the need for a conversion, CUNA wrote. It also urged NCUA to be more flexible (and quicker) to use its merger authority so an FCU does not have to be in steep decline before NCUA allows a merger with another credit union.
- FOM Type Conversions. CUNA said NCUA should permit FCUs that convert to a community charter to keep approved groups in their FOMs that are outside the boundaries of their new community.
- Full Narrative Approach. CUNA urged NCUA to reinstate the pre-2010 narrative approach for defining a community to be used when a community cannot be adequately defined by a statistical area or political jurisdiction. NCUA does not currently allow a narrative approach to document a community. All communities must meet MSA requirements today.
- Process Reform and Transparency. CUNA said NCUA needs to evaluate further the agency’s processes for approving FOM expansion.
- More Access to Underserved Areas for All Credit Unions. CUNA said the agency needs to do more to help credit unions find and serve underserved areas.
CUNA’s comment letter includes section-by-section feedback on the proposed rule. A copy of the CUNA comment letter is available in CUToday.info’s The Gov.