
What's in store for field of membership?
Marc Schaefer, CEO of Truliant Federal Credit Union

Marvin Umholtz, president and CEO, Umholtz Strategic Planning and Consulting Services, Olympia, Wash.
I have long considered the common bond and field-of-membership limitations in the Federal Credit Union Act, and especially as interpreted by the NCUA’s often-confusing rules, to be counter-productive anachronisms that should have been totally repealed long ago.
In this day and age, how crazy is it anyway to limit, via statute and rule, who any entity’s customers can be or where they can be located? That sounds dangerously like a fair lending violation in the making, too. “Excluding” rather than “including,” doesn’t make for good marketing messaging either.
An outright repeal of the statutory FOM limitations would take political guts, but until that political capital is invested in fundamental statutory change, the heartburn of banker vs. credit union FOM expansion lawsuits will continue unabated.
If the credit union industry truly believes the institutions’ mission is not linked to credit unions remaining tiny and limited in scope, then it should stand tall and tackle this ugly FOM beast at its roots – by overhauling the statutes and relevant rules.

Geoff Bacino, former NCUA board member and current partner, Bacino & Associates

Michael M. Bell, legal & business attorney at Howard & Howard Attorneys, Royal Oak, Mich.
John McKechnie, former NCUA and CUNA staffer, now senior partner of the public policy and advocacy firm Total Spectrum, Washington DC

Phil Tschudy, media & reputation strategist, CUNA Mutual Group
