Tuesday, November 17, 2015


The National Credit Union Administration (NCUA) has recently chartered credit unions to serve people that belong to certain religious groups and native American tribes.

For example, on August 28, 2015, NCUA's Office of Consumer Protection chartered a federal credit union to serve members and employees of the Redeemed Christian Church of God North America, Inc. NCUA also chartered a federal credit union on July 7 of this year to serve employees, members, synods and member congregations of the Evangelical Lutheran Church in America.

While these two credit unions have a common bond, it is unclear to me how these institutions' common bonds are in compliance with the Equal Credit Opportunity Act (ECOA).

ECOA makes it unlawful for any creditor to discriminate against any applicant with respect to any aspect of a credit transaction on the basis of race, color, religion, national origin, sex or marital status, or age.

Does NCUA give these credit unions a waiver with respect to complying with ECOA? Or does the agency not even consider ECOA when considering a charter application from a group for a credit union?

It is my opinion that NCUA should not charter a credit union that would appear to be out of compliance with ECOA.

1 comment:

  1. Sorry, membership in a credit union and selling shares as part of a savings or checking account is not a "credit transaction." In the words that a former bank trade association person would understand, those limitations are "common bonds."



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