“While I'm not a military member, I paid into one of their sponsored organizations, Voices for America's Troops, with a $15 membership fee,” Calonia said of how she joined PenFed.

Calonia said she was excited to have discovered she could join PenFed, and because she's had a good member experience, wanted to share the information with consumers.

Is this method of recruiting new members compatible with common bond requirements set forth in the Federal Credit Union Act and the NCUA's Field of Membership Manual?

PenFed spokeswoman Tawnya Lancaster declined to comment on the article.

The NCUA requires that associations wishing to partner with credit unions to offer membership to their list of benefits maintain bylaws, a membership list, meetings and have dues requirements. However, there is nothing in the rules that prevents a credit union from using associations as a catch-all for those who aren't otherwise eligible for membership.

Examiners do check for compliance within field of membership limitations when there is a concern or a suspicion that the credit union is not complying with the established limits, said NCUA spokesman John Fairbanks.

“In cases where membership growth is unusual or there may be indicators the credit union membership screening process is not well-controlled, examiners may perform sample testing during the exam,” he said.

Birmingham, Ala.-based industry consultant and former NCUA Board Member Dennis Dollar said there's nothing wrong with collaborative arrangements between credit unions and associations that generate new members for both.

“More and more associations are seeing the value in these relationships, as are a number of SEG-based credit unions looking for additional avenues for membership growth,” Dollar told Credit Union Times. “As long as the association is legitimate, this is good marketing for both the association and the credit union.”

Meeting regulatory requirements is good enough for the NCUA, but what about the impression left on consumers like Calonia, who thinks credit union common bond requirements are a myth?

American Bankers Association Senior Economist Keith Leggett said the practice abuses and devalues the credit union charter, and that it makes the case for Congress to repeal the credit union tax exemption.