Despite recent activity, the NCUA has said it is not in the business of pushing mergers in 2012. According to an agency spokesman, there is "an upsurge in mergers this year which is likely due to the ability of continuing credit unions to assume the responsibilities associated with mergers as economic conditions stabilize."

It still may be unclear on the promotion of both voluntary and involuntary mergers and perhaps charting new ground on field of membership, some industry watchers contend. What might be more apparent is the NCUA's Office of Consumer Protection apparently emerging as the clearing unit on FOM questions as they relate to prospective mergers.

In the area of exclusion clauses, Chris Conway, president/CEO of the $392 million Educational Systems FCU in Greenbelt, Md., said he has been told by friends that the NCUA may be more open to removing them in the future.