Should its sponsor broaden its common bond requirements,Thrivent Federal Credit Union will have to submit its sponsor's newbylaws to the NCUA for review to make sure its field of membershipremains in accord with the agency's regulations, according to anNCUA letter.

ThriventFinancial for Lutherans, the $75 billion insurance andfinancial services mutual company sponsors the $478 million,45,000-member TFCU, which it formed last year from the consumer lending and deposit takingbusiness of a bank that it owns.

The sponsoring firm's members face a vote starting in Marchabout whether to expand the firm's common bond for membership fromLutheran to Christian, raising the possibility that it might alsosharply expand the credit union's field of membership.

That possibility drew a protest letter this week from the American BankersAssociation, raising questions about whether TFL's moving itscommon bond from Lutheran to Christian might mean the Appleton,Wis.-based credit union adopts an illegally broad FOM.

“ABA believes that the National Credit Union Administration(NCUA) has an affirmative obligation to limit this type ofexpansion,” wrote ABA Senior Economist Keith Leggett in the Feb. 4letter to the agency. “The NCUA needs to ensure a genuineaffiliation between credit union members, as Congressmandated.”

The agency responded with a letter, also on Feb. 4, which saidthat if TFL changed its common bond from Lutheran to Christian,TFCU would have to submit the organization's bylaws to the agencyfor review of their impact on its FOM.

Citing the agency's Interpretive Ruling and Policy Statement08-2, Gail Laster, director of the NCUA's Office of ConsumerProtection, wrote: “In the event a change occurs, Thrivent FederalCredit Union would need to submit the sponsor's revised bylaws tothis office for review to ensure the sponsor continues to meetNCUA's associational common bond requirements.”

Laster did not indicate how long such a review process mighttake or what steps the agency might take if it found TFL's newcommon bond, should it occur, was too broad for TFCU's field ofmembership.

The agency did not say whether any credit unions in the pasthave faced similar situations or how they were resolved.

Meanwhile, TFL has been somewhat surprised at the attention thispotential change to its common bond has drawn, and Brett Weinberg,communications director for the firm, challenged the notion thatmaking that change would mean TFCU would be throwing open its doorsto Christians generally.

“[T]o be a credit union member, an individual must still becomea Thrivent member or otherwise meet the credit union's eligibilityrequirements, such as being a credit union employee or Thriventemployee,” he wrote in an email response to a question fromCredit Union Times.

“It is not correct to say that any Christian could join ThriventFederal Credit Union if Thrivent's membership did vote to extendits common bond,” Weinberg said. “The credit union's membershipwould still be primarily restricted to those who meet Thrivent'seligibility criteria and who actually join the fraternal benefitsociety.”

In addition, he noted that the making the common bond had beenin discussion at the firm for some time and actually predated thecreation of the credit union.

“In addition, the purpose of the potential extension is to allowus to help more Christians be wise with money and live generously”Weinberg added. “The potential impact on the credit union field ofmembership simply did not play a factor in the decision to moveforward with the member vote.”