Compliance: NCUA legal opinion on contiguous boundaries

NCUA’s latest legal opinion letter addresses contiguous geographic boundaries, recognizing that several Hawaiian islands can be contiguous for the purposes of the agency’s rural district regulation, despite being separated by a body of water.

NCUA General Counsel Michael McKenna points out that the opinion is limited to the “unique factual circumstances” described in the letter.

According to McKenna, the proposed geographic area met the criteria required.

NCUA’s chartering manual provides that an area of any geographic size qualifies as a rural district if:

  • The area has well-defined, contiguous geographic boundaries;
  • The total population of the district doesn’t exceed 1 million;


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