NCUA’s field of membership proposed rule and secondary members


Happy Monday, compliance friends! Today we’re going to talk about the National Credit Union Administration’s (NCUA) proposed rule regarding chartering and field of membership (FOM) regulations. Specifically, the portion dealing with the eligibility of immediate family members of decedents.

Current Rule

You can either be a primary or a secondary member of a credit union. Regarding primary members, NCUA Legal Opinion 97-1020 provides that “[a]n FCU may include in its FOM those individuals who share a common bond of occupation, association, or community.” The legal opinion goes on to state that “[t]hese individuals are considered primary members of the FCU.” Essentially, a primary member falls within the field of membership (FOM) as defined in the credit union’s charter (the credit union’s FOM is found in Section 5 of its charter).

When it comes to secondary members, NCUA’s Chartering and Field of Membership Manual states that:

“A number of persons, by virtue of their close relationship to a common bond group, may be included, at the charter applicant’s option, in the field of membership. These include the following:


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