CCUL letter applauds NCUA proposed changes to FOM rules
Thursday, February 11, 2016
Carolinas Credit Union League (CCUL) VP Regulatory and Compliance Counsel Jeanne Couchois on Monday, February 8 submitted to the National Credit Union Administration (NCUA) the League's comment letter on the NCUA proposed rule to amend field-of-membership (FOM) regulations. Tuesday marked the NCUA deadline for comments, which also were invited directly from credit union leadership and staff via grassroots advocacy tools Power Comment and Voter Voice, both provided by the Credit Union National Association (CUNA).
League comments were crafted with input from member credit unions and were favorable on nearly all provisions, which would affect community, multiple common bond, and trade, industry, or profession (TIP) charters. Proposed changes also address definitions of other eligible persons, rural districts, and underserved areas.
“Many industry parties have expressed their concerns that the federal charter is more rigid and burdensome than some state charters and thus less attractive," Couchois recognizes in the letter. "The proposed rule represents a step forward in easing the burden and restrictions of the federal credit union charter while “enhancing the menu of strategic options for FOM expansions.”
While in agreement with two proposed aspects, the League recommends adjusted approaches.
- On the proposal to extend the population limit for a Core-Based Statistical Area to be qualified as Well-Defined Local Community (WDLC), CCUL encourages elimination of the limit since it is not a requirement under the Federal Credit Union Act and a Core Based Statistical Area is by definition a WLDC.
- On the proposed broadened definition of a TIP to include employees of entities with strong dependency relationships within the same industry, the League suggests consideration of additional options such as interdependency relationships with sponsors.
"(T)he proposal provides some regulatory relief and recognizes that federal credit unions are better positioned than mere statistical data to define what qualifies as a community," Couchois concludes. "The proposed changes offer all three types of charters more options to grow and thrive."
View the full letter »