Is the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA Combined Statistical Area A Well-Defined Local Community?

The National Credit Union Administration (NCUA) Board is proposing to quadruple the population threshold of a presumptive community charter consisting of a statistical area or a portion thereof served by a federal credit union (FCU) to 10 million.

The Board defines a statistical area as being comprised by a Combined Statistical Area or a Core-Based Statistical Area (CBSA). A CBSA is either a Metropolitan or Micropolitan Statistical Area.

For example, if the proposed population threshold of 10 million is approved, this would allow an FCU to serve a statistical area as a well-defined local community (WDLC) with a population that is greater than the population of 41 states and the District of Columbia.

In addition, the proposal would qualify 20 additional Combined Statistical Areas as presumptive WDLCs. This means that all but two Combined Statistical Areas would qualify as presumptive WDLCs.

Under the proposal, the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA Combined Statistical Area would qualify as a presumptive WDLC.

The Washington-Baltimore-Arlington, DC-MD-VA-WV-PA Combined Statistical Area has an estimated population of approximately 9.6 million people. This is below the proposed 10 million population threshold.

The region encompasses one county in southern Pennsylvania, portions of the eastern panhandle of West Virginia, central and southern Maryland including part of the eastern shore, the District of Columbia, and northern Virginia.

It includes six Metropolitan Statistical Areas and two Micropolitan Statistical Areas.

This region has numerous trade areas, multiple taxing authorities, and multiple political jurisdictions.

In my opinion, the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA Combined Statistical Area is hardly a local community; but rather a region.