The proposed size of the community is too small, the definition of rural is too arbitrary and the requirements on marketing plans are too burdensome. Those are among the most frequent complaints in comment letters about the NCUA's proposed rule to revamp the way the agency approves community charter applications.

The agency wants to designate a well- defined local community as one having 2.5 million or fewer people and have a core area containing 50% of the jobs and 33% of the population.

NAFCU Executive Vice President Dan Berger wrote that the numbers spelled out are "arbitrary and capricious" and noted that many areas would qualify as local communities but fail because they have more than 2.5 million people. He noted that of the 21 metropolitan statistical areas with more than 2.5 million people, 15 lack a city or county with at least 2.5 million people.