Last November, the NCUA Board issued its proposed rule on fieldof membership. On Oct. 27, having received approximately 11,000comment letters, the NCUA is coming full circle. The agency isscheduled to finalize its field of membership proposal and proposea new field of membership rule.

If the NCUA addresses many of the concerns NAFCU and our membershave submitted to the agency, the new FOM rule will help ease someof the stifling regulatory burden that hinders credit unions’ability to develop and serve their communities. Clearly, consumersare interested in credit unions — membership has reached nearly 105million — and credit unions would like to serve more but areprevented from doing so based on existing regulations.

By any standard, these changes are long overdue.

The NCUA’s proposal represents the first major review of thecommon-bond requirements related to community, multiple-group andtrade, industry or profession charter types in more than 10years.

In today’s challenging competitive marketplace, NAFCU supportsthe NCUA’s FOM rule as a necessary measure that will allow creditunions to keep pace with state law changes as well as technologyand the progress of the financial services industry. We believe theNCUA is acting well within its legal authority to removenon-statutory constraints on chartering and FOM expansion, and tostreamline its procedures.

While last year’s proposed FOM rule was a solid step forward,NAFCU has also urged that more be done to give the industryregulatory relief, including: Eliminating or substantiallyincreasing the core-based statistical area population cap,establishing a formal notification process for credit unions makingFOM-related applications, and considering new ways to efficientlyauthorize mergers. We hope Thursday’s final rule and subsequentproposal deal with the issues that NAFCU and our members havecommunicated throughout the public comment period.

In the end, we look forward to reviewing the NCUA’s final andnew proposed FOM rules. We appreciate the agency’s thoughtfulapproach to addressing this critical issue and hope this approachwill be reflected in the finished rule.

Credit unions have been stymied in their efforts to be morecompetitive and extend services to many who would greatly benefitfrom them. Consumers merit the choice of a financial institutionthat puts them first. We hope the NCUA’s new FOM rule will helpmake that a reality.

B. Dan Berger is president/CEO of NAFCU. He can be reachedat 703-522-4770 or [email protected].