Monday, January 11, 2016

Is an Industrial or Office Park a SEG or Community?

In its proposed field of membership (FOM) rule, the National Credit Union Administration (NCUA) Board is proposing to permit a multiple common bond credit union to include as a select employee group (SEG) the employees of a park’s tenants (e.g., retail tenants of a shopping mall, business tenants of an office building or complex).

However, NCUA has previously recognized an industrial park, shopping mall, office complex, or similar development as a special type of community charter.

The inclusion of a community in a multiple common bond charter would violate the Federal Credit Union Act (FCUA). The FCUA limits a federal credit union’s FOM to one of the following -- a single common bond credit union, multiple common bond credit union, or community credit union.

The FCUA does not permit a hybrid charter comprised of a community and multiple common bond charter, except when a multiple common bond credit union adds an underserved area to its FOM.

This begs the question -- is an industrial or office park a special type of community or a select employee group?

NCUA cannot have it both ways.
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2 comments:

  1. AnonymousJanuary 11, 2016 at 7:49 AM

    For a well informed and smart guy, you are really off on this one.
    NCUA and credit unions have it both and MANY ways and have had so for years.
    It's called violating fom rules though all means available and they're good at it.
    You think every indirect auto loan is "kosher"?
    You think all those pseudo linked associations are "legal"?
    So far, congress has been the credit union bff.
    Maintains tax exemption, cheats on field of membership, grandfathers Mbls, the classic Heisman with the LID designation, etc.
    What lawmaker once said of NCUA that it's a rogue agency?

    ReplyDelete
  2. AnonymousJanuary 11, 2016 at 8:01 AM

    Have it both ways already.
    Why do the medallion lenders have concentrations of Mbls at 60-70+%?
    Isn't a medallion a small biz loan?

    ReplyDelete

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