Latest deregulatory proposal would eliminate burdensome FOM requirement

Chartering and field of membership common bond requirements are the focus in the NCUA’s ninth round of Deregulation Project proposals. Issued Tuesday, they amend requirements in the Chartering and Field of Membership Manual to increase flexibility.

Specifically, it would remove the automatic disqualification of associational groups currently in place that requires the purchase of a product or service as a condition. Instead, it would allow the NCUA to take a case-by-case approach examining the “totality of the circumstances” to determine whether the customer relationship is only incidental to the group’s overall purpose.

America’s Credit Unions will review the proposal in detail and release a Regulatory Comment alert with information and comment deadlines.