WASHINGTON (2/1/16)--There are just seven days until the comment period closes on proposed modernizations of the National Credit Union Administration's (NCUA) field-of-membership (FOM) regulations, which set the rules determining who credit unions can have as members.

The Credit Union National Association (CUNA) strongly supports the proposed improvements, along with the NCUA’s efforts to streamline the agency’s FOM processes. CUNA urges credit unions to voice support of the agency’s plan by the Feb. 8 deadline.

National and state bank trade associations are hot on the heels of the issue, sending hundreds of letters not only to the NCUA, but also to congressional leaders.

“Their activity serves as an important reminder that we need to continue to make our voice heard,” said Ryan Donovan, CUNA chief advocacy officer.

In a letter to Congress last week, CUNA President/CEO Jim Nussle took the American Bankers Association and Independent Community Bankers Association to task for the “factually incorrect” letters sent to Congress.

CUNA’s resources include a detailed summary of the proposal and a comment letter guide to support credit unions as they develop substantive comment letters.

State credit union leagues also are in the forefront, encouraging member credit unions to submit their input and offering resources to build effective comment letters. “It is important that our regulator hears from significantly more credit unions than banks on this issue, and that we counter those inaccuracies with the facts," said John Murphy, Maine Credit Union League president (Weekly Update Jan. 29). The Northwest Credit Union Association (NWCUA) has set a goal of 1,000 letters of support from all 157 Northwest credit unions, John Trull, NWCUA assistant vice president of regulatory advocacy (Anthem Jan. 29).

The proposal was issued for comment at the NCUA board’s November meeting and carries a number of changes CUNA advocated for, including:

• Allowing rural districts to be comprised of up to 1 million residents by changing the standard used to measure it. That is four times greater than the current cap of 250,000;
• Allowing a congressional district to be considered a "well-defined local community" to support a community charter application;
• Eliminating a geographic limitation on trade, industry or profession charters for federal credit unions with associational common bond memberships; and
• Streamlining the paperwork and process to allow credit unions to add groups with up to 5,000 potential members to be added to a multiple common bond federal credit union. The current rule limits these groups to 3,000 potential members.