During First-of-Its-Kind Public Hearing, Support Expressed for CU’s FOM Expansion Request

WASHINGTON—During a first-of-its-kind virtual public hearing hosted by NCUA, NAFCU testified in favor of a request by Dade County Federal Credit Union’s to expand its field of membership (FOM).

Andrew Morris

The trade group said the CU’s application “represents an important step towards putting modern and flexible field of membership expansion procedures into practice.”

As CUToday.info reported earlier, DCFCU is pursuing the FOM expansion through the narrative approach under the NCUA’s FOM II rule, which took effect in September 2018 and requires that a credit union explain why a particular area falls within its FOM. For statistical areas that exceed the 2.5 million population limit, a public hearing is also required.

The credit union’s current FOM covers Miami-Dade County, Fla., and its request would expand to include Broward County to the north. NAFCU Senior Counsel for Research and Policy Andrew Morris said during the hearing the counties reside within the same Metropolitan Statistical Area, according to the U.S. Census Bureau, and he further highlighted their social cohesion and economic interconnectedness.

‘Compelling Evidence’

“DCFCU has provided compelling evidence that it has both the ability and the intent to serve its requested community,” said Morris. “DCFCU has persuasively demonstrated through its application that it is able to meet the NCUA’s requirements for narrative based field of membership expansion. Accordingly, NAFCU supports DCFCU’s request to serve Broward County. We also support the NCUA demonstrating, through a straightforward approval of DCFCU’s application to join an additional county to its existing field of membership, that a narrative-based model can serve as a viable tool for helping federal credit unions grow and remain healthy.”

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