Monday, January 4, 2016
Community Charters that Don't Meet the Definition of Local Should Be Subject to Public Comment
Back in 2007, the National Credit Union Administration (NCUA) Board recommended that a community charter application from an FCU that does not meet the established presumptive definition of local be subject to public notice.
The time is right for the NCUA Board to resurrect this idea.
The NCUA Board should publish a notice in the Federal Register and on its website seeking comment on whether the proposed community charter application is a local well-defined community.
The NCUA Board should give interested parties sufficient time to comment on the proposed charter application.
I know some in the credit union industry would hate this idea.
However, public comment would provide for a more complete record and would assist NCUA with its analysis of whether the area in question is a well-defined local community.
NCUA should not simply rubber stamp information provided by an FCU showing interaction and common interests among residents in the proposed community.
The time is right for the NCUA Board to resurrect this idea.
The NCUA Board should publish a notice in the Federal Register and on its website seeking comment on whether the proposed community charter application is a local well-defined community.
The NCUA Board should give interested parties sufficient time to comment on the proposed charter application.
I know some in the credit union industry would hate this idea.
However, public comment would provide for a more complete record and would assist NCUA with its analysis of whether the area in question is a well-defined local community.
NCUA should not simply rubber stamp information provided by an FCU showing interaction and common interests among residents in the proposed community.
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