Credit unions are anxiously anticipating the NCUA board'smonthly meeting Nov. 19, thanks to a field of membership proposalon the agenda.

Federal credit unions are demanding FOM regulatory relief, andstate regulators' ability to draft less restrictive rules hasspurred a new flight away from the federal charter, as ViceChairman Rick Metsger pointed out back in March. At the time,credit unions were converting to state charters at a three-to-onerate compared to conversions from state to federal.

Stakeholders will soon find out which restrictions the NCUA willlift within its legal authority. But will it be enough to level theplaying field?

The NCUA could significantly expand the geographic range ofcommunity and TIP charters. Credit unions are correct when they saythe current well-defined local community population cap of 2.5million is arbitrary and not required by the Federal Credit UnionAct.

CUNA recommended in its comment letter the NCUA should allowfederal credit unions to serve a combination of contiguouscommunities and single political jurisdictions that do not exceed atotal population of 10 million or a land area of 20,000 squaremiles. NAFCU recommended the agency eliminate the capaltogether.

Tinkering with the definition and expanding the cap would onlyreplace an arbitrary number with another arbitrary number. It'sinteresting CUNA used the greater Los Angeles area as an example inits comment letter. The letter describes Los Angeles County as itsown community and San Bernardino County as another community,thanks to separate political jurisdictions.

I live in Riverside County, which, like San Bernardino County,is considered part of the greater Los Angeles metro area. When Itravel and am asked where I live, I say LA. We share the same newschannels, drive the same freeways and many of my neighbors commuteinto LA every day for work. We are part of the Los Angelescommunity, which has a total population of more than 18 million. Acredit union should be able to serve that community, and a 10million cap wouldn't accomplish that.

The NCUA could make the bold move of eliminating the cap, aswell as raising or eliminating limits that define a rural district.However, doing so would draw the ire of the banking lobby and couldresult in lawsuits. (Then again, anything that is good for creditunions angers bankers and could result in lawsuits.)

I predict the NCUA will follow the more prudent route andpropose larger caps.

The NCUA may be more liberal in its easing of geographiclimitations on TIP charters. The shared trade, industry orprofession required of members by the charter is the common bond,not physical location. Perhaps geography could be argued as part ofthe definition of a local community in court, but it's completelyunnecessary for TIP charters.

Service facility requirements for SEG-based charters could alsoget an overhaul. The NCUA could update its definition of servicefacility to include technology like mobile deposit, but it stillfaces a reasonable proximity requirement in the FCUA that ispresumed to be physical, not digital.

We all know technology has expanded the ability of financialinstitutions to serve consumers anywhere in the world, and non-bankcompetitors that don't have that compliance requirement are anincreasingly competitive threat. Congress needs to address that ifit expects federally insured depository institutions tosurvive.

Technology has even changed how Americans define theircommunity. Most people spend more time interacting with fellowmembers of a shared common social bond on Facebook than they dotalking to their next door neighbors. Congress needs to addressthis too.

Geographical limits aren't placed on all cooperatives; I canorder a snowboard from REI online, pay my $20 membership fee and bedone with it. Geography was an acceptable political compromise whenmembers accessed their accounts in person, but times have changed.There's no reason a credit union that would serve the LGBTcommunity should be restricted by geography.

I don't think the NCUA will make significant FOM merger changes.Allowing two credit unions with different charters to merge forstrategic reasons would force the NCUA to redefine its charters. Idon't think the agency is prepared to go that far.