Blasts from the past – Resources on serving business accounts

Some credit unions historically have not served businesses, but may revisit that decision from time to time. For credit unions that may be considering how to help businesses in their communities, here is a round up of past blogs and other NAFCU resources on this topic as well as a few other things to consider.

Field of Membership

Field of membership requirements can be one initial issue.  For FCUs, a business or other organization can become a member three key ways depending on the credit union’s charter: (1) it is located in a community charter FCU’s area; (2) it is specifically named in the FCU’s charter as a member; or (3) it is an “organization of” persons who are within the FCU’s field of membership. This Compliance Blog post provides a refresher on how these components work. State-chartered credit unions will need to refer to their particular state provisions.  Overall though, credit unions that currently do not serve businesses may need to make changes to their fields of membership in order to begin doing so, especially multiple common bond charters.

Applicability of Various Regulations

Many of the rules governing accounts or loans specifically apply to consumers and not businesses. That is not always the case though, this past blog post identifies some of the key regulations that may still apply to business accounts, and this other post details lending provisions that can apply for businesses. This post explains when Regulation Z may apply to a business purpose credit card, in the context of liability for unauthorized use. NCUA also has a commercial loan rule, distinguishing between member business loans and commercial loans. In some cases, a credit union would need to develop robust policies and procedures to offer “commercial loans” to members. This past blog post has some details on which loans are commercial loans, although legislation in 2018 removed one kind of loan from the prior statutory definition of MBL.


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