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NAFCU urged NCUA to streamline its field of membership chartering and expansion procedures and to remove non-statutory constraints in a letter Wednesday detailing recommendations made by its Field of Membership Taskforce.

"As NCUA considers amending its current Chartering and FOM Manual, NAFCU and our members encourage the agency to fully utilize its statutory authority to provide requisite relief to our industry," wrote NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt. "While we acknowledge that legislation is necessary to relax aspects of the Federal Credit Union Act's limitations on chartering, we firmly believe that NCUA can enact constructive regulatory relief today by streamlining its chartering and FOM procedures, as well as removing all non-statutory constraints on FOM chartering and expansion."

Hunt also said, "We are grateful to NCUA Board Chairman Debbie Matz, Vice Chairman Rick Metsger and Member Mark McWatters for their support for modernizing the agency's field of membership regulations, and we look forward to working with them to provide credit unions with relief in this area."

NAFCU sent NCUA a policy paper summarizing the concerns and recommendations from its members and from the taskforce, which was made up of more than 50 member credit unions of various asset sizes and charter types.

In addition to removing non-statutory requirements that impose geographic limitations on FOM chartering and expansion, NAFCU made the following recommendations:

• update the Chartering and FOM Manual, which has not been changed since 2003, to reflect the current process;
• require deadlines for NCUA to respond to FOM amendment requests;
• increase transparency in the decision-making process regarding FOM-related applications, with a formal notification process and regular status updates about applications;
• remove the arbitrary 2.5 million population cap for "well-defined local communities," as it is not mandated by the Federal Credit Union Act; and
• revise the "rural district" definition to allow deserving communities to qualify.

NAFCU also strongly urged NCUA to end its limitation on a single- or multi-associational chartered FCU from continuing to serve its existing FOM when it converts to a community charter, unless the associational and occupational groups are entirely within the new community.

FOM changes are a major focus of NAFCU's "Top Ten Regulations to Eliminate or Amend" and its "Five Point Plan for Regulatory Relief." The association will continue to work with NCUA to push for FOM relief within its current statutory authority.