According to the American Bankers Association, NCUA has illegally permitted credit unions "to leapfrog their way into new cities, counties, and even new states using this "underserved" exception to common bond requirements." In an attachment to the memo to Congress, ABA cited examples of what it deemed to be illegal expansions: * Paragon FCU, of Montvale, New Jersey, added two counties in southwestern Pennsylvania – about 400 miles and a six-hour drive away. * US FCU, of Burnsville, Minnesota, which added Fulton County, Georgia, and Shelby County, Tennessee, using the underserved provision. * Sunwest FCU, a $265 million community credit union charter primarily located in Phoenix, added the city of Tucson, Arizona, and its 500,000 population base under the "underserved" designation, thus allowing Sunwest to have a footprint in the two largest population centers in Arizona. * L & N FCU, a $463 million community charter in the greater Louisville, Ky., area, added a number of counties in Kentucky and Ohio, including portions of the city of Cincinnati, some 100 miles away from Louisville, under the "underserved" designation. * Robins FCU, a $900 million credit union in Warner Robins, Georgia, added Clarke County, home of the University of Georgia, to its FOM in July 2003, arguing that it was underserved. Clarke County is more than a two-hour drive from the credit union's main office.