CUNA Comment Letter

NCUA Proposes Field Of Membership Policy Changes For Federal Credit Unions

February 3, 2003

Ms. Becky Baker
Secretary to the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3486

Re: Proposed Changes to NCUA's Chartering and Field of Membership Manual for Federal Credit Unions (Interpretative Ruling and Policy Statement 02-5)

Dear Ms. Baker:

On behalf of the Credit Union National Association, I am pleased to submit comments to the National Credit Union Administration on the Board's proposal to expand field of membership opportunities for federal credit unions, without jeopardizing safety and soundness or contravening any applicable statutory constraints under the Federal Credit Union Act. By way of background, CUNA represents more than 90% of the nation's over 10,000 state and federal credit unions. This letter was developed under the auspices of CUNA's Federal Credit Unions Subcommittee, chaired by Mr. Chris Jillson, President and CEO of Sandia Laboratory Federal Credit Union, Albuquerque, New Mexico.

Summary of CUNA's Position