ALEXANDRIA, Va. — The national credit union trade associations, while generally supporting NCUA's proposed changes to its Field of Membership and Chartering Manual, asked NCUA to reassess the requirement for notice to be published in the Federal Register.
CUNA and NAFCU each said some type of public notice might be appropriate for those community fields of membership that do not meet the prescribed definitions but the publication in the Federal Register may be too much as well as not helpful. For consistency with other financial regulators, NAFCU recommended public notice and comment, similar to the Office of Thrift Supervisions' Weekly Bulletin. CUNA recommended an additional, separate comment period on this portion of the proposed FOM amendments.
The groups applauded the addition of core-based statistical areas as pre-defined communities not requiring addition documentation. However, the definition of a rural area was too limiting, according to CUNA and NAFCU. CUNA suggested that maximum population of 100,000 for a rural area be removed altogether while NAFCU recommended increasing it to 250,000.
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Predictably the banker groups weighed in as well opposed to the expansion of the pre-designated communities and in favor of the limitations in the proposal, such as the five-year cap on previously approved communities. The Independent Community Bankers of America opposed any pre-designation of communities.
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