The National Credit Union Administration (NCUA) Board is proposing to allow a Combined Statistical Area with a population limit of 2.5 million to be treated as a de facto well-defined local community.
According to the Office of Management and Budget (OMB), there are currently 169 Combined Statistical Areas. These Combined Statistical Areas are comprised of 524 Core-based Statistical Areas. A Core-based Statistical Area is either a Metropolitan or Micropolitan Statistical Area.
According to 2013 Census Bureau estimates, only 20 Combined Statistical Areas exceeded the population threshold of 2.5 million.
OMB introduced the concept of Combined Statistical Area in 2000. OMB stated that Combined Statistical Areas can be characterized as representing larger regions that reflect broader social and economic interactions, such as wholesaling, commodity distribution, and weekend recreation activities.
However, two Federal Courts ruled against NCUA in Utah and Pennsylvania, when the agency approved community charters comprised of multiple core-based statistical areas. The Federal Courts wrote that the areas did not meet the requirement of being well-defined local community.
So, how can a larger region represented by a Combined Statistical Area meet the requirement of being a local community?
NCUA is clearly trying to accomplish through the regulatory process what it has not been able to do legislatively.
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