NAFCU letter to NCUA on associational common bonds

(June 30, 2014) — Good morning,

Attached is NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt’s letter to the National Credit Union Administration (NCUA) regarding the agency’s request for comment on the proposed rule on the associational common bond requirements in the Chartering and Field of Membership Manual.

In the letter, Hunt says that NAFCU supports the legitimate growth of credit union industry and encourages every legal avenue that credit unions have to expand their field of membership, which is why the association cannot support aspects of the proposed rule.

Hunt also says that NAFCU believes the threshold requirement regarding the proposed rule is subjective, inappropriate and unnecessary. “Because NCUA’s Chartering and Field of Membership Manual currently requires the agency to evaluate an application by the totality of the circumstances,” Hunt wrote “NAFCU believes that adding a step before this evaluation is unnecessary. NCUA should not look at certain factors in a vacuum and create a mere administrative bar.”

Hunt also raised concerns and questions regarding NCUA’s ongoing Quality Assurance Review process.

If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.

Thank you.

Dana Kauffman
Communications Coordinator
National Association of Federal Credit Unions
3138 10th Street North
Arlington, VA 22201
Phone: 703-842-2235
Fax: 703-524-1082

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