CUNA strongly supports the NCUA’s second proposed field-of-membership (FOM) rule, as it contains important changes CUNA recommended to the agency over the past 18 months. The proposal was issued in October as additional FOM modernizations to the rule finalized by the NCUA board at the same meeting.
“We appreciate the agency adopting CUNA’s suggestions that will help credit unions serve more Americans, whose access to consumer-friendly and affordable financial services should not be limited by outdated regulations adopted when financial services were delivered differently,” the letter reads.
The two major CUNA suggestions incorporated into the proposal are:
Also in the letter, CUNA spelled out why the Federal Credit Union Act grants the NCUA the authority to make the proposed changes.
CUNA believes, based on a review of the major provisions of the proposal, that it falls well within the agency’s statutory authority.
Congress has delegated the authority to the NCUA to interpret the Federal Credit Union Act in this matter, has properly exercised its authority to make the regulation and has reasonably interpreted the Federal Credit Union Act in putting the proposal forth