adminAfter years of litigation brought by banks, NCUA has finalized its most recent amendments to the field of membership rule for federal credit unions. The rule makes three changes to the federal field of membership and will be effective on Oct. 14 or 30 days from the date of publication.
First, it allows a community chartered credit union to use a Combined Statistical Area (or a portion of that area) from census data to delineate the required Well Defined Local Community that may consist of a population of up to 2.5 million people.
Second, in relation to those community charters using the Core Based Statistical Area (or a portion of that area) to formulate a well-defined local community, they will no longer be required to serve the core area.
Finally, NCUA is modifying the application for these community charters to ensure a credit union is not discriminating against minorities or underserved populations in its decision of which communities to serve.
NASCUS recently hosted a webinar on the field of membership changes presented by credit union attorney David Reed. If you would like to see this webinar, you can contact Mike Lee to request access to it from NASCUS. Also, If you would like to review the litigation history of the rule, NCUA’s exhaustive response to the ABA’s comments on the rule, or their legal arguments from the litigation, including examples of how the rule change has improved the ability of federal credit unions to serve those communities, you can review the rule here.
Our comment letter on this most recent iteration of this rule can be found here.
