Carrie Hunt At NAFCU, we try every day to make the world a bit better for credit unions and their members. Strengthening the federal charter is at the core of our advocacy. We push for change on many different fronts, and making the regulatory regime better bit by bit is one way we reinforce the charter. But many times our efforts come to a screeching halt because of an assertion that we need a change in the Federal Credit Union Act.

The NCUA made no secret of the fact that its number one legislative priority in 2014 was to seek third-party vendor examination authority. As NCUA is an independent regulatory body that regulates credit unions, NAFCU found it puzzling that the agency chose to ignore the plethora of other legislative changes that would actually make credit unions stronger. Field of membership changes certainly would have been at the top of our list to effect positive change for credit unions.

The NCUA has taken a significant step in setting up a working group to examine field of membership issues, but changes to FOM requirements have been talked about for years. We already know what needs to be done:

Federal credit unions need to be able to merge and blend fields of membership more easily than under the current rules – and not just in an emergency situation.
Federal credit unions need to be able to add underserved areas to their FOMs no matter what the charter type.
Federal credit unions need, at a minimum, wild-card parity with state FOM rules relative to geographic limitations.

NAFCU has suggested legislative changes in our five-point plan for credit union regulatory relief to improve FOM limitations, but we call on the NCUA to do more now. The NCUA can provide federal credit unions more flexibility through revisions to existing rules. NAFCU stands ready to work with NCUA to make credit unions stronger – and we need to start right now.

Carrie R. Hunt is NAFCU's senior vice president of government affairs and the trade's general counsel. She can be reached at

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NCUA and FOM: Hiding Behind the Law

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