WASHINGTON–The American Bankers Association told NCUA it opposes a proposed rule to expand field of membership rules.
In a comment letter, the trade group said a proposal to significantly expand federal credit unions’ field of membership to include out-of-state remote workers and noncontiguous rural districts will result “in a pathway for FCUs to obtain a nationwide FOM.”
“This is contrary to statutory intent that FCUs maintain a local presence and common bond among members,” the ABA said.
Specific Opposition
Specifically, the ABA expressed opposition to the inclusion of remote workers in a community FCU’s FOM, arguing “it further dilutes the common bond requirement. It is illogical to assume an employee working for a company headquartered in Oregon, but working remotely in California, has a
‘meaningful affinity’ or ‘routine interaction’ with people residing in Oregon who do not work for that same company.”
Instead, ABA is recommending credit unions that want to add an occupational group to their community charter be required to apply for a multiple common bond (MCB) charter, with the group saying such a move would more accurately reflect the different constituencies the credit union plans to serve.
Additional Changes
As CUToday.info reported earlier, the proposed rule would also:
- Remove the eligibility requirement for MCB FCUs that additions in underserved areas based in rural districts be in a state bordering the state of the credit union’s headquarters.
- Simplifies the statement of unmet needs that an FCU must submit when requesting to add an underserved area to its FOM.
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