Bankers' opposition to the NCUA's field of membership proposal has reached a heightened rhetoric, calling to mind their battle with credit unions that took place almost two decades ago. The comment period for the proposal ended on Feb. 8, with comments totaling nearly 11,000 letters, NCUA Chairman Debbie Matz noted during a Feb. 9 Town Hall webinar.

The NCUA's FOM proposal is so hotly contested by the banking industry that comment letters from the American Bankers Association and Independent Community Bankers Association have prompted trade organizations to go on the offensive in order to clarify what they see as errors in banking trades' letters to the NCUA and Congress.

In November 2015, before the NCUA board even met to discuss the FOM proposal, the ABA began attacking it. At that time, incoming ABA President/CEO Rob Nichols said the proposal stepped outside the bounds laid out by Congress.