Community charters and remote access to a community

As NAFCU noted last week, the House passed a bill that, among other things, would permit federal credit unions to add underserved areas to their field of membership. The bill also adds “banking deserts” to the definition of an underserved area. Under the bill, banking deserts are areas not within 10 miles of a branch of a financial institution. While this bill is not effective and must still pass the Senate, I thought I would take the time to discuss a topic that comes up quite a bit on the Compliance Helpline. Specifically, what is a community-chartered federal credit union’s field of membership and does remote appearance in a community or rural district qualify a person for membership.

According to NCUA’s field of membership manual there are two types of community-chartered FCUs. The first type is “based on a single, geographically well-defined local community or neighborhood.” The second type is a well-defined rural district. Depending on the FCU’s charter, there are four potential ways that a person can qualify for membership in a community-chartered FCU. These are:

• Persons who live in the community or rural district;
• Worship in the community or rural district;

 

continue reading »