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."

NAFCU has also put forth key solutions that the NCUA should support now, including:

  • 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 recommended legislative changes in our five-point plan, as well as regulatory action in our "Dirty Dozen," to address current FOM restrictions. Pursuing legislative changes and making regulatory revisions, however, are not mutually exclusive activities. The NCUA can offer federal credit unions more flexibility through revisions to existing FOM rules, while the industry and the agency pursue legislative changes on the Hill. NAFCU is ready and willing to work with NCUA to strengthen the federal credit union charter– and there's not a minute to lose.  

Alicia Nealon

Director of Regulatory Affairs

NAFCU

Arlington, Va.

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