Newsroom

February 09, 2016

NCUA: 10,500 FOM comments, so far

As of Tuesday, NCUA had received 10,500 comment letters in response to its proposed field-of-membership rule, the agency said.

NAFCU Director of Regulatory Affairs Alicia Nealon noted that number is a record amount of comments for NCUA, which she said underscores how necessary this regulatory relief is.

"The record number of comments exemplifies how engaged credit unions are on this issue. Field of membership and the ability to reach the modern consumer are pivotal to our industry's transition into the 21st century," said Nealon. "NAFCU hopes that NCUA will finalize a rule that incorporates many of the suggestions raised by credit unions in these comment letters so that our industry will receive relief needed to compete in today's rapidly innovating financial services marketplace."

NAFCU sent a letter in support of the rule on Friday with several recommendations for how the rule might provide more comprehensive regulatory relief for credit unions. The deadline for comments was Monday.

NAFCU has also shared the letter with leaders on Capitol Hill, where the association has been active throughout the process debunking false claims made by banking trades about the proposal.

In the letter, Berger wrote that NAFCU and its members strongly believe more can and should be done to bring the credit union industry into the 21st century. Along that line, he urged NCUA to make several additional changes as its prepares its final rule:

  • eliminate or increase the core-based statistical area population;
  • add a de novo narrative approach to the statistical methods used to classify "well-defined local communities";
  • either remove the service facility requirement for multiple-common-bond charters or allow credit union online services to demonstrate their presence in underserved areas;
  • recognize retired federal employees and retired teachers as affinity groups;
  • allow single- or multi-associational chartered federal credit unions that convert to community charters to continue to serve their previous associational and occupational groups; and
  • consider ways to more efficiently authorize mergers.

Berger also recommended that NCUA adopt a maximum 30-day window for the Office of Consumer Protection to review FOM amendment requests. Berger also urged the agency to establish a formal notification process when reviewing credit unions' FOM-related applications so credit unions can have regular status updates.

The proposed rule, issued in November, would make substantive changes affecting the common-bond requirements associated with community, multiple-group, and trade, industry or profession charter types. It represents the first major revamp on these charter types in more than 10 years.