In a comment letter to NCUA, CUNA has outlined four changes to field of membership rules to change what it calls "unnecessary limits."
Saying it supports the agency's current proposal for revisions to its Chartering and Field of Membership Manual for FCUs (Interpretative Ruling and Policy Statement 02-5), CUNA said its four suggestions would "help make a fine proposal even better." Those proposed changes include:
* Expansion and clarification of the concept of a common bond based on a trade, industry, or profession (TIP) to remove more unnecessary limits. CUNA said the concept could be broadened without jeopardizing any directives or violating any prohibitions of the Federal Credit Union Act.
* Empowerment of multiple-group federal credit unions (as well as FCUs with a single occupational common bond) to add groups based on a TIP. CUNA told NCUA that the Act does not "preclude a multiple-group FCU from including a TIP in its FOM, consistent with other limits that would apply to group additions."
* Enabling FCUs that have a substantial interest in an ATM or a network to include new members based on ATM locations-as long as there's a sufficient, demonstrable indication of support from the FCU for the area to be served, CUNA wrote.
Allowing FCUs to use a shared service facility for purposes of adding new members, even if they don't have an ownership interest in the facility-as long as the FCU's participation in the facility results in a demonstrable connection with the service area.
CUNA said its proposals and that of NCUA "are within the law and "fully compatible with reasonable principles of safety and soundness" in supporting FCUs' ability to grow."
In its letter, CUNA reiterated its support for NCUA's plan to vastly curtail the need for overlap analyses; eliminate an economic analysis for groups under 3,000 to determine if each group could sustain a separate FCU; presume that any city, county, or smaller political jurisdiction is a local community, regardless of size, if other conditions are met; presume that any metropolitan statistical area (MSA) or equivalent (or portion thereof), up to one-million residents, is a local community, and other proposals.
