The NCUA formed a field of membership working group consisting of agency staff and industry representatives; it is still in its early stages, Matz said.

While the group has been meeting internally to develop a plan of action, the NCUA has not yet brought in any stakeholders. Matz said the group plans to examine possible field of membership changes the agency could implement without legislative action.

"It's a little early to determine what changes the NCUA is likely to propose or even when that's going to happen, because it really depends on what changes the working group recommends and how soon they recommend them," Matz said. "We didn't give them a timeline because I want them to take whatever time they need to really be thorough, vet all the issues and give us some options as well as the pros and cons of each option."

While Matz said she hopes the agency can act on field of membership changes this calendar year, the timing depends on how quickly the working group makes its final recommendations.

NCUA Vice Chairman Rick Metsger said the agency could permit credit unions that convert from single or multiple common bonds to community charters to continue serving their select employer groups even if they are located outside the new community charter boundary.

"That's something we might be able to do here at the NCUA and that would potentially persuade more credit unions to consider converting to a federal community charter," he said.

Matz agreed.

"If the working group can look at what the statutory limitations are and how we can work within those to expand the field of membership, that would be great," she said. "They can take another look at the whole idea of including SEGs when the agency grants community charters. If the SEG is in a community right now, they can't serve that SEG. They can continue to serve the existing members, but they can't serve that SEG. I know that's been a thorn in the side of credit unions."

Matz said she views the potential change as a way to prevent mergers. The NCUA approved 268 mergers in 2014.

"They could expand their field of membership without having to merge. If there is some way we can do that within the statutory constraints, I would like to see them move in that direction," she said. "My goal would be for there to be fewer mergers and for credit unions to be able to maintain their independence and have a viable charter."

Metsger said another proposed change could be to eliminate non-community chartered credit unions from the computation method used to determine if an area is underserved, which includes bank facilities listed by the FDIC and all credit union branches.

"If they are not a community credit union, they can only serve their SEG, right? So, why would we count them as saying they are serving the area when they are actually limited to serving particular members?" Metsger said.

Metsger also suggested that the agency allow active duty military and their families to automatically qualify as low-income. The agency considers students low-income, but Metsger pointed out that national statistics show members of the military often fall into the low-income category.

"This change would provide greater flexibility in allowing credit unions with a high concentration of active duty military personnel to receive the low-income designation," he said. "Not only does that provide significant reg relief in some areas, but it also provides some waivers for them, such as with member business lending."

Metsger said field of membership rules are connected to the amount of credit unions converting from federal to state charters.

"Many states are advancing their state charters on a biennial basis and thus widening the disparity between who federal and state credit unions in the same market can serve and what they can offer consumers," Metsger said in a February speech to the Education Credit Union Council.

"While the overall number of charter changes has gone down the past few years, the pendulum is now skewing heavily from federal to state charters at almost a three-to one pace over the last four years. Over a similar four-year time period a decade ago conversions ran nearly two-to-one in the other direction," he added.

NCUA Board Member J. Mark McWatters encouraged the NCUA to "amend its field of membership regulations in a progressive and dynamic manner to the maximum extent possible." McWatters said he wants the agency to "enhance the ability of the traditionally underserved to join credit unions and obtain loans and other financial services at fair, non-confiscatory rates and permit credit unions to expand their scope of operations and extend more job creating small business loans to Main Street."

The $914 million Rogue Credit Union in Medford, Ore., cited field of membership restrictions as a reason for its decision to convert from a federal to state charter on Jan. 1.

"Over the last several years, Rogue Credit Union has strategically evaluated our field of membership and future growth opportunities," President/CEO Gene Pelham said. "This analysis showed that with our considerable deposit and loan market share in the communities that we currently serve we needed to identify long-term future market expansion opportunities. Our sincere desire was to remain a federally chartered credit union, but we found that the existing NCUA field of membership rules provided no opportunity for Rogue Credit Union to expand."

"NAFCU believes the NCUA should have a reverse wild card authority where federal credit unions can request a waiver from the agency that allows them to follow a state rule for credit unions if it allows them to serve their members better," Carrie Hunt, NAFCU SVP of government affairs and general counsel, said.

"I don't know how much to expect from Congress in the short term though. So for right now, the attention and the action is going to be at the NCUA," CUNA Chief Advocacy Officer Ryan Donovan said.

CUNA is in the process of reaching out to credit unions and leagues for more input on FOM. The trade group has asked the NCUA to allow credit unions that convert from state to federal charters to continue adding new members from all previous groups. CUNA also requested the NCUA revisit a range of community credit union requirements.