Dear Heather,
First of all, congratulations to you and your colleagues on the Credit Union Times' 25th anniversary! The publication has been a valuable sentinel of the credit union industry and has helped shine a light on many noteworthy events and issues over the years.
On that point, NAFCU appreciates your astute comments about the issues that will indeed have significant impact on the industry going forward: field of membership and chartering rules.
Without substantive changes now in both these areas, credit unions will face an increasingly challenging and uncertain future. NAFCU has recommended legislative changes in our five-point plan, as well as regulatory action in our “Dirty Dozen,” to address current field-of -membership restrictions.
Here are some of the things that NAFCU has identified that can be done:
- Federal credit unions need to be able to merge and blend fields of membership more easily than under the current rules – and not just in an emergency situation.
- Federal credit unions need to be able to add underserved areas to their FOMs no matter what the charter type.
- Federal credit unions need, at a minimum, wild-card parity with state FOM rules relative to geographic limitations.
In the meantime, NCUA can provide credit unions more flexibility to current rules. We welcome working with NCUA to help bring about these much-needed changes.
Again, congratulations and many more sterling years of success!
Carrie Hunt
SVP of Government Affairs and General Counsel
NAFCU
Arlington, Va.
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