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January 12, 2021

CUs: Offer insight on NCUA’s service facility definition modernization

Reg AlertNAFCU sent members a Regulatory Alert Monday outlining the NCUA's proposed rule to modernize the definition of a "service facility" for multiple common bond (MCB) federal credit unions (FCUs).

In the Regulatory Alert, NAFCU highlighted that the rule as proposed would include any credit union ATM or a shared branch, shared ATM, or shared electronic facility in the definition of “service facility” – regardless of whether the FCU is an owner of the shared branch network. The proposal also seeks comment on whether digital banking access such as websites or mobile banking applications should be considered in the definition of service facilities, for which NAFCU has advocated.

NAFCU noted that this recognition of the use of shared branching facilities and ATMs should ease a credit union’s ability to meet the “service facility” requirements in serving underserved communities and adding select groups to their field of membership (FOM).

NAFCU posed several questions in the Regulatory Alert for credit unions to consider for feedback. Comments on the proposed rule are due to NAFCU Feb. 8; comments are due to the NCUA Feb. 10.

For more on the proposed changes, including an in-depth section-by-section analysis, view the Regulatory Alertsubscribe to receive Regulatory Alerts.