June 05, 2014

Members' input due on associational common bond

June 6, 2014 – Today is the deadline for NAFCU members to submit their input to the association's official comment letter on proposed changes to the associational common bond provisions of NCUA's chartering and field-of-membership manual.

The proposed rule was issued in April, and NCUA is accepting comments on it until June 30. Members' input received through today will be used in formulating NAFCU's official comment.

If adopted in its current form, the proposal would establish a threshold requirement that would be applied before any factors in the "totality of the circumstances" test are considered. If NCUA determines based on the threshold test that an association was primarily formed for the purpose of expanding credit union membership, the application would be rejected outright.

The proposed rule would also add an eighth factor – corporate separateness – to the list of factors reviewed under current rules, and it would grant automatic qualification under the associational common bond rules to certain categories of groups.

NAFCU published a Regulatory Alert for members and is taking comments online.