WASHINGTON, DC (May 27, 2026) |
The Defense Credit Union Council (DCUC) has filed a comment letter in support of the National Credit Union Administration’s (NCUA) proposed rulemaking to amend associational common bond requirements for chartering and field of membership (FOM).
The proposal would amend language in the NCUA’s Chartering and Field of Membership Manual to clarify that requiring the purchase of a product or service as a condition of membership does not automatically disqualify an otherwise legitimate association from the Federal Credit Union Act's associational common bond provisions. Instead, in reviewing applications to determine eligibility, the NCUA would consider the entirety of the circumstances such as the group’s structure, scope and degree of its activities, and other operational factors to conclude whether its relationship with its members is primarily or incidentally a client-customer relationship.
DCUC supports the NCUA's proposed change because it more accurately reflects the statutory intent of the FCUA and the revised example better clarifies the requirements for an associational common bond. This amendment will help many credit unions navigate the field of membership requirements.
“DCUC appreciates the NCUA Board’s efforts to modernize and streamline the agency’s regulatory requirements while preserving operational flexibility for credit unions,” the letter stated. “We look forward to continuing to work with the NCUA on future initiatives that enhance regulatory clarity, improve operational flexibility, and reduce unnecessary compliance burden.”