SALT LAKE CITY-NCUA and its fellow defendants have filed a brief supporting their strong belief that the agency's approval of a six-county field of membership for Tooele Federal Credit Union and subsequent others. The 31-page memorandum in opposition to plaintiffs' motion to invalidate agency action filed July 12 provides details in support of the credit union organizations' positions and why the banker-plaintiffs are wrong in their accusations that NCUA overstepped its bounds. NCUA and the intervenors, including CUNA, NAFCU, the Utah League of Credit Unions, and four targeted credit unions, argue that the agency did follow proper review procedures and made its decision based on relevant matters. In conclusion, the memorandum stated, "The administrative record contains ample evidence demonstrating that the six-county area approved for Tooele FCU meets the criteria for a "well-defined local community" under the CUMAA and the regulations adopted pursuant to the Act. NCUA properly exercised its expertise and discretion in deciding that Tooele FCU's application-and consequently the applications of the America First, Goldenwest, and University of Utah credit unions-merited approval for federal credit union community charters. NCUA's decision is entitled to substantial deference under the APA." The bankers have until July 30 to file their reply.