NAFCU is delighted that Sarah Snell Cooke's Feb. 4 Credit Union Times editorial, "Field of Membership Needs a Complete Overhaul," echoes our concerns about the NCUA's field of membership rules and our call for long-overdue changes.

While the NCUA has taken a step toward change in setting up a working group to examine FOM issues, credit unions need action now.  We have lost more than 1,000 credit unions, at a clip of over 200 per year since the implementation of the Dodd-Frank Act. Simply put, credit unions cannot afford to have the NCUA continue to study the issue without implementing some changes.

In her commentary, Cooke highlights some of the shortcomings with NCUA's current interpretation of many elements of the Credit Union Membership Access Act, further underscoring the concerns NAFCU expressed in our earlier editorial, "NCUA and FOM: Hiding Behind the Law."

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