ALEXANDRIA, Va.—NCUA is reminding that when it comes to field of membership expansion requests by credit unions a “community application based on the narrative approach must include evidence that clearly supports that the proposed area qualifies as a well-defined local community.”
The statement is included in NCUA’s latest quarterly newsletter in which the agency details how credit unions can submit requests to serve a local community using the narrative approach.
The article walks credit unions through using the narrative approach in their applications, noting that a community application based on this approach must "include evidence that clearly supports that the proposed area qualifies as a well-defined local community. …[A]n applicant must provide the NCUA with sufficient information to support how the area's residents interact or share common interests."
13 Criteria
This narrative approach falls under the NCUA's second field-of-membership (FOM) rule, which became effective Sept. 1, 2018. Under the FOM II rule, credit unions seeking to form, expand or convert to a community charter are given the option of submitting a narrative as to why a particular area meets their field of membership. In addition, for statistical areas that may exceed the 2.5 million population limit, narrative applications will be subject to a public hearing, NAFCU noted in its analysis.
The agency said there are 13 narrative criteria that identify a well-defined local community.
With the American Bankers Association challenging NCUA’s new FOM rules in court, NAFCU said in a statement it supports the agency.
“The association has stood by the agency as its original FOM rule is challenged by bankers; NAFCU believes these FOM reforms fall well within the agency's legal authority,” NAFCU stated.