Lots of Acronyms in Play in NCUA's Merger Approval Process

ALEXANDRIA, Va. – The Mid-States Corporate FCU/Minnesota Corporate FCU merger is in full swing as NCUA has received the paperwork, so what happens next? With so many corporate mergers in recent years, it’s worth looking at what the corporate merger process is at NCUA. The Office of Corporate Credit Unions is responsible for making sure any corporate merger is in compliance with Part 708 of NCUA’s Rules and Regulations. Mergers must also be in the best interest of both the merging and continuing corporate credit unions in NCUA’s eyes. The first official step in any corporate merger is preparation of the merger plan. For this, corporates follow the procedures in the Credit Union Merger Procedures and Merger Forms Manual, which is designed for natural person CUs, but applicable for corporates. Corporates must make some adjustments such as calculating capital ratios as defined by Part 704, not the Probable Asset Share Ratio. Each board of the respective corporates must also fill out some paperwork for NCUA. For the continuing corporate it’s form 6302, and 6303 for the merging corporate. The corporates will also have to complete form 6301, Application for Approval of Merger Checklist, and other related forms. Once the merger proposal is officially submitted to the OCCU it will be assigned to the Corporate Program Specialist (CPS), who will review it to ensure all the necessary forms are included. The CPS will forward a copy to the Corporate Examiner (CE), who will then have up to 30-days to review the proposal. The CE is also responsible for looking at safety and soundness, operational, and financial issues. Any questions that arise, the CE will contact the corporate directly. Eventually, the CE will prepare a memorandum to the OCCU Director with a recommendation for approval or disapproval of the merger request. If for some reason the CE recommends against the merger, specific reasons must be given. The CE will also forward the memorandum to the Corporate Field Supervisor, who will review it and if the CFS concurs with the CE’s recommendation, will forward it to the OCCU Director. The CPS will review the merger proposal and the recommendations made by the CE and CFS. Once the CPS has all the necessary information, it will prepare the Board Action Memorandum, which will be forwarded to the OCCU Deputy Director and the OCCU Director. It is then up to the NCUA Board to approve or disapprove the BAM. [email protected]