NCUA’s proposal would update the chartering manual’s service facility requirements which would help credit unions deliver necessary financial services to Americans and has CUNA’s strong support. The proposal would include any shared branch, ATM where the credit union is a member of the network, or  electronic facility in the definition of “service facility” for a federal credit union adding an underserved area.

“The proposed rule would make common sense changes to service facility requirements and reduces regulatory burden and confusion by harmonizing requirements for multiple common bond (MCB) credit unions for group and underserved area additions,” the letter reads, also noting that the proposed changes simplify requirements while adding necessary flexibility needed for credit unions to serve underserved areas.

CUNA also strongly encourages NCUA to include transactional websites and mobile banking applications in the final rule’s definition of service facilities as “contemplated but not proposed” in the proposed rule.

“The pandemic has established that transactional websites and mobile banking applications are a critical, and possibly the most, important means of delivering financial services making appropriate to include them in the definition of service facilities, because credit unions are already successfully using them as service facilities,” the letter reads.