ensure that credit unions that need to grow will be able to do so under the federal charter. And the rule is also likely to receive unanimous approval by the NCUA Board since the proposed rule received the affirmative vote of all three board members. NAFCU's efforts to enhance the federal charter have provided critical momentum to some of the most important changes in the proposed rule, including greater member access and additional opportunities for federal credit unions to diversify their membership. Nowhere is this more evident than in the proposed trade, industry and professional (TIP) common bond. As far back as October 1998, NAFCU noted its belief that the agency was being too restrictive in its interpretation of the common bond to require employment by the same or related agency or other legal entity that shares a commonality of ownership. This led us to say in our comments on IRPS 99-1 and IRPS 00-1 that NCUA's "focus should be on the bonds that bring the employees together…for example, all healthcare workers, all public servants or all employees of the same franchise." Although these suggestions were not included in the 1999 or 2000 FOM changes, it is now clear that the seeds were planted for the proposed TIP common bond to be finalized this week. Back when we first engaged the agency on FOM issues, we stated that it was our firm belief-and our members' experience-that NCUA was making the SEG addition approval process overly burdensome. There was a sense of frustration with the agency and a feeling that the size of SEGs that could qualify for an expedited approval process, at that time 200, was far too low. We learned that of those SEGs that were disapproved – even to the level above 3,000 – not a one formed their own credit union. The result, therefore, was something that no one desired -a denial of credit union services to America's consumers. The difference from where we started and today could not be sharper. The timeline for SEG application approvals has been considerably shortened, as evidenced by an analysis we conducted last year that shows approval rates have jumped dramatically while deferrals have dropped off. Now NCUA is on the verge of approving an expedited process for adding SEGs of less than 3,000 to multiple bond credit unions, something that we have been pushing towards since February 2000. This is indeed a gratifying turnaround for the agency, and one for which we all should thank Chairman Dollar and the other NCUA Board members. Another welcome change is NCUA's proposed definition of "service facility" for multiple-group credit union expansions to include wholly-owned ATMs and shared service facilities if there is an ownership interest. NAFCU has long sought such an overhaul in this definition. However, it is important to note that some credit unions have chosen to invest in cooperative ATM networks rather than purchase ATMs. As more and more credit unions choose this option, NAFCU believes such credit unions should not be penalized for making prudent business decisions to provide their members with a higher level of service. Furthermore, such restrictions may serve to hurt expansion opportunities for smaller credit unions that choose to participate in ATM or shared branch networks on a non-ownership basis. Accordingly, NAFCU has encouraged the board to go a step further and permit credit unions to take advantage of such non-ownership alternatives. A topic of conversation that has come up many times in our discussions with NCUA is what constitutes a "local community." We have argued that based on the lack of legislative history, recent court decisions, and the definitions of "local community" adopted by other regulatory agencies, NCUA could further liberalize the rules for credit unions wishing to serve a community. We are pleased to see the agency's proposed criteria for determining a community as either a single political jurisdiction, metropolitan statistical area (MSA) or multiple political jurisdictions and view this as a dramatic improvement for those credit unions wishing to obtain a community charter. With the adoption of these field of membership changes, one could say we have passed through a thicket following the triumph of CUMAA and now find ourselves in a clearing where we should, or could, pause briefly; but that will not be the case. From the beginning, we have clearly indicated that there is work to be done on both sides of the Potomac River, at NCUA and on Capitol Hill. Our efforts of late have become increasingly focused on Congress, where we soon expect to see introduced a reincarnation of last year's Regulatory Relief bill. This measure will include vital provisions that must be dealt with legislatively to enhance credit union growth and innovation, including allowing community-SEG combinations. Charter conversions remain a concern as well. In the January, actions taken under NCUA's delegated authority, seven federal credit unions converted to state-chartered credit unions with combined assets of $1 billion. The trend may slow and perhaps even reverse at some point, but that will not change NAFCU's determination to continue to enhance the federal charter and preserve its unique qualities. We also must be prepared for fresh legal attacks from the bankers. The banks tried to block NCUA's regulatory implementation of CUMAA, but credit unions prevailed with victories at both the federal trial and appellate court levels. The courts acknowledged that NCUA's field of membership rules were firmly within, as Chairman Dollar often says, the "letter and spirit" of CUMAA. Nevertheless, don't be surprised if the banks once again seek legal action following the promulgation of this rule. NCUA Chairman Dennis Dollar, Vice Chair JoAnn Johnson and Board Member Deborah Matz deserve tremendous credit for taking on these field of membership issues. NAFCU greatly appreciated the opportunity to present its views to the Board members, the FOM Task Force and other NCUA staff, and it looks forward to continuing the dialogue. The hallmark of this chairman has been the fair evaluation of substantive comments and concerns by NCUA's stakeholders, and this proposed rule is a prime example of that philosophy.