On June 1 I asked the following question -- how is Salt Lake County still part of America First Federal Credit Union's field of membership, if it is a multiple common bond credit union?
From documents obtained through a Freedom of Information Act request, it appears that the credit union retained Salt Lake County via an emergency merger of Intermountain Credit Union on November 1, 2008.
At the time of the emergency merger, America First had a community charter serving Salt Lake County. Intermountain Credit Union's field of membership (FOM) contained Salt Lake County and select employee groups and associations.
Under NCUA's emergency merger regulations, America First can continue to serve Intermountain's FOM, even though Intermountain's FOM was more expansive than America First's FOM.
Almost six years later on July 14, 2014, America First FCU applied to the National Credit Union Administration (NCUA) to convert from a community charter to a multiple common bond credit union. On August 21, 2014, NCUA approved the conversion.
So, America First removed Salt Lake County from its charter; but was able to retain Salt Lake County because it was part of Intermountain's charter at the time of the emergency merger.
But it seems to me that the emergency merger was meant to allow America First to incorporate these select employee groups and associations into its field of membership. There was already an overlap of Salt Lake County in each credit unions' fields of membership.
In my opinion, Salt Lake County should have been struck from both charters at the time America First became a multiple common bond credit union.
Where was the OCC/FRB when First Interstate Bank had interstate branching despite federal law prohibiting it? When that was happening in the 1970s, was the ABA against that expansion of banking powers in excess of explicit federal law?
ReplyDelete