Today, if a federal credit union acquires premises for future expansion but doesn't occupy 100% of that space within a year, its board must put a resolution in place by the end of that year with plans for full occupation. The proposed rule ditches the full-occupancy requirement, the one-year deadline and the board-resolution requirement. Instead, federal credit unions would need to occupy at least 50% of their premises within six years of acquisition.

That opens the door to new sources of noninterest income, because credit unions could rent out more of their unused or unnecessary space, Ross noted.

“Providing people with extra little streams of income here and there that can be grouped together add up at the end of the day in a positive way on a balance sheet,” he said.

The NCUA — which has received comments on this subject since at least 2013 — said the change could also help credit unions get better space.

“Commenters have noted that some local zoning or mixed-use ordinances, city entitlements, or other use requirements may require a portion of the property to be dedicated to retail business,” it said in the proposed rule.

Lurking in the proposal, however, is the temptation for federal credit unions to speculate on real estate, become de facto property developers or full-time landlords.

“The proposed change is required to avoid unnecessarily imposing undue hardship on federal credit unions that may have difficulty realizing their growth potential and member service strategies under the current rule,” it added. “The board emphasizes, however, that it maintains its current view that there is no authority in the Federal Credit Union Act for a federal credit union to invest in real estate for speculative purposes or to otherwise engage in real estate activities that do not generally support its purpose of providing financial services to its members.”

That shouldn't be a problem, according to Ross.

“I think the experience is that credit unions are planners, and they plan for thoughtful allocation of resources,” he said. “Nobody's really beating down the door to invest huge amounts in brick and mortar that they don't need. What this proposal is about is if you have got a few extra square feet of space can I reasonably plan to rent that out or lease that out to a third party with a resulting financial benefit to the credit union? That's, at the end of the day, all this is really about in my view.”

The window for public comment closes on June 27. See the proposed rule here.