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DENVER – When the state Financial Services Board meets for its regular monthly October 12, one of the items on the agenda will be is amending the Division of Financial Services’ field-of-membership expansion policy of multi-state state chartered credit unions with branches in Colorado. Commissioner David Paul said the policy currently on the books is “unclear” concerning to what extent the division is authorized to allow out-of-state state-chartered credit unions with branches in Colorado to expand their field-of-membership beyond the occupational group they were brought into Colorado to serve. There are currently six out-of-state state-chartered credit unions that have branches in Colorado. For example, United Airlines Employees Credit Union headquartered in Chicago, also has a branch in Denver since the city is a United Airlines hub. Paul confirmed he has received a number of inquiries concerning the field-of-membership expansions. At press time, Paul said he planned to make two recommendations to the board at the upcoming meeting: first, the expansion of these credit unions to serve employee groups or occupational groups would be permitted as long as the credit union’s home state offers reciprocal treatment for Colorado credit unions that want to expand their field-of-membership in that state. As for out-of-state credit unions that apply for community field-of-membership expansion, Paul intends to recommend to the board that the division does not have the authority to approve community FOM expansion requests for out-of-state credit unions. “The board and the commissioner under their delegated authority have to determine how a community field-of-membership expansion would affect the safety and soundness of the credit union,” said Paul. “As the host state regulator, we don’t have the jurisdiction to determine that for an out-of-state credit union. We cannot determine the financial impact of such an expansion on the community or the credit union.” Paul said it’s different for Colorado CUs applying for community FOM expansions because “we know those credit unions well enough to make the determination,” but as for the out-of-state CUs, “we don’t have the jurisdiction.” The policy amendment will be decided by board vote on October 12 and will be effective immediately. It will not be retroactive. Paul said he ran the issue and his proposed recommendations by the Colorado Credit Union System and credit unions and it was not controversial among them. He does not expect the league or credit unions to oppose his recommendation at the board meeting. “Our credit unions feel it’s only fair that if we allow out-of-state credit unions that are operating branches in the state to expand their field-of-membership that they should be allowed to do the same in those states,” said Paul. – [email protected]

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