NCUA official seal NCUA official seal. (Source: NCUA)

In the next several months it is quite possible that the NCUA board will be taking final action on its December 2020 proposed rule to consider shared branching and ATMs as credit union service facilities for field of membership purposes. This action is long overdue and, frankly, should have been done 20 years ago when I was at the NCUA. If the Credit Union Membership Access Act had been more mature and technology had become the leading means of access for most credit union members as much then as it is today, I believe we would have made this move during my NCUA tenure. I wish we had stepped out to do so nonetheless based upon the technological delivery of services we were seeing at the time. Credit unions would have been much more competitive and, with the ability to compete in a dynamically changing marketplace, even safer and sounder than they are already today. Mea culpa on that missed opportunity.

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