ALEXANDRIA, Va.—America’s Credit Unions voiced support for the NCUA’s proposed field-of-membership rule, saying the measure would modernize current requirements and expand access to credit union membership for more consumers. The proposal, released as part of the agency’s ongoing Deregulation Project, would make several changes to existing field-of-membership standards.
As written, the proposal clarifies that requiring the purchase of a product or service as a condition of membership does not automatically disqualify an associational group, provided the client-customer relationship remains incidental to the group's activities and overall circumstances.
“The proposed rule appropriately replaces that bar with a determination based on the entirety of the circumstances, expands consumer access to credit union services, and provides measured regulatory relief to federal credit unions,” reads America’s Credit Unions’ comments to NCUA.
America's Credit Unions supports the proposed factors for evaluating whether a client-customer relationship is incidental, and we request that the Board supplement those factors with additional guidance and illustrative examples in the final rule.
“This additional guidance would reduce uncertainty for credit unions preparing applications, promote consistent determinations across NCUA staff and regions, and reduce the need for appeals of field of membership determinations,” the letter adds.