let more consumers qualify for membership. Writing in comment letters filed last month, the Credit Union National Association and the National Association of Federal Credit Unions said a proposed membership rule was too restrictive. CUNA said the National Credit Union Administration should clarify that the law lets a family member of someone eligible join a credit union, even if his relative does not. "We urge the board to allow family membership to be based on an individual's relationship to a potential member" rather than just to actual members, CUNA president Daniel A. Mica wrote. The difference is huge. According to NAFCU, 44 million Americans are members of federal credit unions, but an additional 69 million who are directly eligible for membership do not join. Under CUNA's interpretation of the credit union law, family members of either group could join. As a result, virtually every American could qualify for membership. For example, a New York City artist whose brother is a fireman in San Francisco could join a Bay Area fireman's credit union, even if her brother did not. Mary Mitchell Dunn, CUNA's associate general counsel, said CUNA just wants to maintain the status quo. Credit unions already are allowed to let relatives of eligible nonmembers join, she said, but the NCUA's Aug. 31 proposal did not say whether the policy would be retained. An official said the agency would clarify its position in the final rule, which will be voted on at a Dec. 17 board meeting. NAFCU said the credit union regulator should make in-laws, aunts, uncles, and cousins of members eligible for membership, even if they do not live under the same roof with the member. The proposed rule already would let parents, grandparents, spouses, siblings, children, and grandchildren of a credit union member do so. NAFCU also said that people who live with a member should be able to join whether or not they are related to the member. That includes unmarried partners and domestic employees, such as a live-in maid or nurse. CUNA also suggested that NCUA raise its 300,000 population limit on the size of community-based credit unions. Similarly, NAFCU said that a community credit union should be permitted to include more than one rural county in its field of membership. Under the credit union law, Congress will have 60 days to reject NCUA's definitions of "family member" and "community." But even if they had the vote, they would need a presidential signature to send it back for a rewrite.

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