WASHINGTON (2/3/16 UPDATED 5:30 p.m. ET)--The Credit Union National Association (CUNA) fully supports the proposed field-of-membership modifications from the National Credit Union Administration (NCUA), but believes the agency can go even farther under its legal authority to provide regulatory relief. CUNA filed its comment letter on the proposal today,ahead of the Feb. 8 deadline.
“CUNA strongly supports this modernization effort and encourages the NCUA board to quickly adopt all of the proposed changes along with our additional suggestions, which will make NCUA’s proposal even more robust,” the letter reads. “We applaud NCUA for recognizing the stagnant nature of the agency’s FOM requirements when compared to some innovative state charters.”
The changes are needed because credit unions and CUNA are concerned that the federal charter is falling behind many state charters, thus it has become a barrier to the flexibility needed to operate dynamic and efficient cooperative financial institutions.
Those additional improvements include:
Regarding the provisions already in the proposal, CUNA makes a number of suggestions including raising the rural district population limit to one million people (while grandfathering higher limits allowed under the current rule); raising the threshold to 5,000 employees working at a facility or industrial park to fall in a field of membership (the NCUA proposed a 3,000 limit); and raising the threshold of people in stand-alone groups that can form a new credit union to 10,000.