Field of Membership

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In order for credit unions to best serve Main Street America and everyday Americans in the 21st century, the federal credit union charter must keep pace with changes in state laws, technology, and the financial services industry. Critically, the federal charter must have modern FOM requirements that allow credit unions to meet the needs of communities in today’s financial services marketplace. NAFCU continues to advocate for legislation that would allow all credit unions to add underserved areas to their FOM.

In the previous Congress, Reps. Maxine Waters (D-CA) and Ed Perlmutter (D-CO) introduced the House version of the Expanding Financial Access for Underserved Communities Act, and the Senate companion was introduced by Sen. Alex Padilla (D-CA). This legislation would allow all federal credit unions to apply to the NCUA to expand their FOM to include underserved communities, including communities that lack a depository institution branch within 10 miles. The bill would also exempt loans made by credit unions to businesses in underserved areas from the credit union member business lending cap. The bill passed the House Financial Services Committee by a vote of 27-22 in May 2022 and the text of the legislation was also included as part of H.R. 2543, the Expanding Financial Access for Underserved Communities Act, a larger legislative package that passed the House in June 2022. The Senate version did not advance.


At its February 2023 meeting, the NCUA Board issued a proposed rule on FOM that would streamline the process for multiple common bond credit unions to add underserved areas, amid other changes to reduce paperwork and administrative requirements, as well as changes to credit union membership eligibility to include all immediate family and household members of a deceased member. The proposal would limit eligibility to a six-month period following the decedent’s passing. NAFCU wrote to the NCUA Board to request this change for surviving immediate family in March 2022.