FOM reforms would expand consumer access

The NCUA’s field of membership proposal would adjust current requirements, giving consumers more access to join a credit union. Issued as part of the NCUA’s Deregulation Project, the proposal has America’s Credit Unions’ support as outlined Monday.

As written, the proposal clarifies that requiring the purchase of a product or service as a condition of membership does not automatically disqualify an associational group, provided the client-customer relationship remains incidental to the group's activities and overall circumstances.

“The proposed rule appropriately replaces that bar with a determination based on the entirety of the circumstances, expands consumer access to credit union services, and provides measured regulatory relief to federal credit unions,” reads America’s Credit Unions’ comments to NCUA. 

America's Credit Unions supports the proposed factors for evaluating whether a client-customer relationship is incidental, and we request that the Board supplement those factors with additional guidance and illustrative examples in the final rule.

“This additional guidance would reduce uncertainty for credit unions preparing applications, promote consistent determinations across NCUA staff and regions, and reduce the need for appeals of field of membership determinations,” the letter adds.

Read the full letter