WASHINGTON (1/20/16)--With 20 days remaining before the Feb. 8 deadline to comment on the National Credit Union Association’s (NCUA) field-of-membership (FOM) proposal, the Credit Union National Association (CUNA) has released a new guide to assist in writing those letters. CUNA strongly encourages all credit unions to comment on the proposal.
CUNA issued an action alert in December for the proposal, with President/CEO Jim Nussle calling for letters that “reflect league and credit union official positions on the FOM proposal.”
It is important for credit unions to have a strong, united voice on the proposal, CUNA Chief Advocacy Officer Ryan Donovan has said, particularly to counter bank attacks and threats of litigation against the proposal.
According to the NCUA’s website, more than 1,400 comments have already been received, including letters of support from Reps. John Garamendi (D-Calif.), Brad Sherman (D-Calif.) and Ted Lieu (D-Calif.). The NCUA proposed the rule at its November meeting, and it would modernize FOM regulations by providing flexibility for credit unions and more options for consumers.
According to the NCUA, the proposal will accomplish several objectives:
CUNA has broken down the issues for credit unions with a community charter and multiple common bond credit unions. For each item, CUNA has posted its own position on the matter, followed by several questions that credit unions could seek to answer in their comment letters.