Dear Heather,

First of all, congratulations to you and your colleagues on theCredit Union Times' 25^th anniversary! Thepublication has been a valuable sentinel of the credit unionindustry and has helped shine a light on many noteworthy events andissues over the years.

On that point, NAFCU appreciates your astute comments about theissues that will indeed have significant impact on the industrygoing forward: field of membership and chartering rules.

Without substantive changes now in both these areas, creditunions will face an increasingly challenging and uncertainfuture. NAFCU has recommended legislative changes inour five-point plan, as well as regulatory action in our“Dirty Dozen,” to address current field-of-membership restrictions.

Here are some of the things that NAFCU has identified that canbe done:

• Federal credit unions need to be able to merge and blend fieldsof membership more easily than under the current rules – and notjust in an emergency situation.
• Federal credit unions need to be able to add underserved areasto their FOMs no matter what the charter type.
• Federal credit unions need, at a minimum, wild-card parity withstate FOM rules relative to geographic limitations.

In the meantime, NCUA can provide credit unions more flexibilityto current rules. We welcome working with NCUA to help bring aboutthese much-needed changes.

Again, congratulations and many more sterling years ofsuccess!

Carrie Hunt

SVP of Government Affairs and General Counsel

NAFCU

Arlington, Va.