May 31, 2023

NAFCU asks NCUA to consider additional FOM reforms

NCUA logoNAFCU Regulatory Affairs Counsel Dale Baker Tuesday offered the association’s support for the NCUA’s proposed rule to reform several of the agency’s field of membership requirements (FOM) and definitions, but made some recommendations to strengthen the rule to “further improve Americans’ access to credit union services.”

The proposal includes NAFCU-sought changes to expand membership eligibility to all immediate family and household members of a deceased member. The proposal also aims to enhance consumer access to financial services while reducing administrative burden and streamlining portions of the federal credit union chartering and conversion processes.

Baker asked the NCUA to:

  • maintain the Chartering and Field of Membership Manual’s standalone secondary member groups for surviving spouses, rather than combining it with the group that encompasses other immediate family and household members;
  • extend the proposed six-month secondary member eligibility timeframe for other immediate family and household members to 24 months;
  • amend the manual’s existing secondary member groups for honorably discharged veterans to include both honorably discharged veterans and members of their immediate family or household;
  • strengthen the proposal’s addition of a fifth affinity group for paid employees of a legal entity headquartered in a federal credit union’s community or rural district by expanding it to also include remote students and remote worshippers;
  • further reform credit unions’ ability to add underserved areas to their FOMs and support legislative efforts to do so; and
  • modify the proposed rule’s provisions related to community charter applications and conversions to make the standardized community charter request application available only as an option for prospective applicants and continue to have the option to submit a free-form narrative application.

NAFCU will continue to advocate for FOM reforms to allow credit unions to provide safe, secure, and reliable financial services to Americans who have been left behind by banks and other institutions.