COMMENT CALL: The National Credit Union Administration (NCUA) has announced its ninth round of proposed regulatory changes associated with NCUA’s Deregulation Project. The project is an ongoing review of NCUA’s regulations to ensure they are focused on credit unions’ safety, soundness, and resilience.
Information on the earlier rounds can be found in the “open comment calls” and the “closed comment calls” Regulatory Advocacy pages of our website.
In this round, the NCUA is requesting comments on one new proposal related to chartering and field of membership eligibility. The proposal is summarized below.
Round Nine
- Chartering & field of membership. The NCUA’s proposed amendment would amend the associational common bond provisions of its chartering and field of membership (FOM) rules. It would clarify that requiring the purchase of a product or service as a condition of membership no longer automatically bars eligibility as a recognized association. The NCUA Board said that it does not believe such an automatic bar is required under the Federal Credit Union (FCU) Act, and a client-customer relationship as a condition of membership may still be “incidental” in a way that permits an evaluation of the group’s activities and overall circumstances.
This rule would not affect federally insured state-chartered credit unions, nor FCUs with occupational common bond charters or community charters. It would only change the associational common bond requirements for single and multiple common bond FCUs of all sizes, giving them more freedom to include associations in their FOMs, even if those associations may have some customer-client component.
Make your voice heard
The League may comment on this proposal, depending on the feedback we receive from Wisconsin’s credit unions. Please email Paul Guttormsson with your thoughts on this round of NCUA regulatory relief proposals by June 1, so that our comment letter (which is due June 8) can reflect your positions.
Compliance Roundtable – September 16 (In-Person)
Join a member of The League’s compliance team as they lead a discussion on the latest changes in regulations and need to know information to keep your credit union in compliance. You can find more information or register on our website.