CUNA Regulatory Comment Call


June 7, 2000

NCUA Proposes FOM Policy Changes

(Major Proposal for Federal Credit Unions)

When NCUA developed its current field of membership policies under the Credit Union Membership Access Act, CUNA urged the Board to undertake a one-year review and assess what improvements, if any, should be considered. The Board agreed and directed its Field of Membership Task Force, led by Region V Director Len Skiles, with NCUA Senior Attorney Mike McKenna, to evaluate its policies and make recommendation for any needed changes.

At yesterday’s meeting, the Board issued a number of proposed provisions, which were recommended by the NCUA Task Force following its one-year review. Commentors will have 60 days to respond to most of the changes. A few technical amendments will take effect upon publication in the Federal Register or on an expedited basis, as discussed further below.

Included in the FOM proposal is a provision for CRA-type requirements for federal community credit unions. A separate CUNA Regulatory Comment Call addresses that topic. The other FOM changes NCUA is proposing are intended to streamline the application process and make other modifications to make it easier for credit unions to expand their fields of membership, consistent with the Federal Credit Union Act. Here is the list of changes to NCUA's field of membership policies that, in addition to the CRA-type requirements, the agency is proposing with a sixty-day comment period:

Two items approved by the Board are effective upon publication. These are:

Another two items will be implemented without comment as soon as procedures have been developed. These are an express chartering program and an Intent select group expansion process for occupational groups of 500 or less.

CUNA’s Federal Credit Union Subcommittee, chaired by Ed Collins, President and CEO of Lockheed Georgia Employees FCU, will be developing our comment letter on the amendments. Leagues and credit unions are encouraged to share their views with us.

QUESTIONS TO CONSIDER
(Most of these are issues raised by NCUA)