NAFCU shares support, clarifying recommendations for NCUA’s service facility proposal


In response to the NCUA’s proposed rule to modernize the definition of a “service facility” for multiple common bond (MCB) federal credit unions (FCUs), NAFCU Senior Regulatory Counsel Elizabeth LaBerge shared the association’s support of the rule and offered clarifying suggestions.

“NAFCU and our members have long advocated for NCUA to modernize the Manual in recognition of the advent of technology and its impact on commerce and consumer behavior,” wrote LaBerge. “The proposed rule would define ‘service facility’ in a manner that provides clarity, consistency, and the appropriate recognition of technological advances and the current operation of shared branching.”

As proposed, the rule would include any credit union ATM or a shared branch, shared ATM, or shared electronic facility in the definition of “service facility” – regardless of whether the FCU is an owner of the shared branch network.

NAFCU has long been supportive of efforts to modernize rules relating to field of membership and has highlighted the need for credit unions to be able to access relief and tools to reach underserved communities.


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