Letter to NCUA on Chartering and Field of Membership

Dear Ms. Conyers-Ausbrooks:

The American Bankers Association (ABA) appreciates the opportunity to provide comments to the National Credit Union Administration (NCUA) on a proposed rule (Proposal) that would amend its chartering and field of membership manual (Chartering Manual) related to underserved areas, community-based field of membership (FOM), and other FOM provisions. Specifically, the Proposal would make rule changes for multiple common bond (MCB) federal credit unions (FCUs) that seek to add underserved areas to their FOM. In addition, the Proposal would streamline the application process for community-based FCUs by simplifying the business and marketing plan requirement while eliminating the requirement in its entirety for certain state-chartered credit unions seeking to convert to a federal charter. The Proposal would also expand community-based FOM affinities. As a result, the Proposal, contrary to congressional intent, would authorize significant FOM expansion while undermining FCUs' physical presence in local communities and undercutting the common bond requirement among membership. Therefore, ABA requests that the NCUA withdraw the Proposed Rule in its entirety.

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