The action by the NCUA board in proposing changes to its field of membership regulation has unleashed a fury of activity by the various banking trade organizations in an effort to intimidate the NCUA and fire up the banking community to aggressively oppose the FOM changes.

The initial shot across the bow came from Camden R. Fine, president/CEO of the Independent Community Bankers Association, in November of last year when he threatened litigation "if the NCUA doesn't back off." He called the board's FOM proposal the "last straw."

This month, the American Bankers Association joined the attack by sending a memo to all of its members urging them to write comment letters to the NCUA criticizing and opposing any change to the FOM. The memo, listing Brittany Dengler as the staff contact person at the ABA, stated that "the NCUA is an out of control agency cheerleading, not regulating … the credit union industry." The memo further stated that the NCUA proposal is contrary to congressional intent, urged its members to emphasize in its letters how banks serve their customers and communities, and stated that competition from credit unions negatively impacts the banks' business.