Recent field of membership letters to federal credit unions

The NAFCU compliance team has blogged about field of membership a couple of times over the past few months. The first blog provided an update on the litigation between the American Bankers Association (ABA) and the National Credit Union Administration (NCUA)—litigation that was resolved when the United States Supreme Court denied the ABA’s writ of certiorari and refused to hear an appeal of the decision by the United States Court of Appeals for the D.C. Circuit in which the NCUA prevailed. The second blog discussed NCUA’s final rule, published in September, that permits credit unions applying for approval of a community charter, expansion, or conversion to designate a Combined Statistical Area (CSA) or a distinct, adjoining part of a CSA as a well-defined local community as long as the area has a population of 2.5 million or less.

In the past month, NCUA has issued two letters to federal credit unions, 21-FCU-01 and 21-FCU-03, providing additional guidance to federal credit unions about field of membership issues. The first letter did three things. It provided three templates that federal credit unions can use to convert to or expand a community charter:

  • A business and marketing plan that can be used when a noncommunity charter federal credit union seeks to convert to a community charter or an existing community charter intends to add more than one neighboring area;
  • A streamlined business and marketing plan that can be used when an existing community charter intends to add a neighboring area;


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