The NCUA's recently proposed Home-Based Credit Union Rule, 12 CFR, Part 701, Requirements for Contacts with Federal Credit Unions, has drawn strong criticism from credit unions across the country raising the same concerns I stated when I voted against the proposal at the December 2013 NCUA Board Meeting.

The proposed rule tries to accomplish two things:

1. It moves an examination of a home-based credit union offsite to better aid in the safety of examiners by removing them from private residences. Poor and unsafe working conditions were cited during the board meeting as reasons the rule is necessary.

2. It requires all home-based credit unions to acquire commercial space within two years.

The first initiative is based on examiner safety but limited to federally chartered credit unions only. There are 93 home-based credit unions. Of that number 80 are federally chartered and 13 are state chartered, federally insured. It is believed that an examiner, working alone, could be subject to personal jeopardy if other people are not around.

The second initiative is based on the unfounded belief that member access is limited at a home-based credit union, there is a lack of ability to reach them because of no phone or internet access, and because they are home based there is no potential for growth.