Tuesday, June 2, 2020

NCUA Should Publish Its Analysis

In a May letter to credit unions, the National Credit Union Administration (NCUA) stated that it will no longer exclude military personnel with APO and FPO mailing addresses from calculating whether a credit union qualifies for low-income designation.

This decision was based upon analysis by the agency's Office of Chief Economist, which determined that the majority of military personnel would qualify as low-income members.

However, NCUA has not published the analysis of the Office of Chief Economist.

If NCUA had subjected this action to the rulemaking process, it would have had to disclose details of this analysis.

The agency needs to make public its analysis. It should also make public the data behind the analysis.


  1. Seems like a bit of overkill when the Agency only wants to exclude members who were being improperly evaluated previously, no?

    All the new rule states is the foreign military members will be assigned a proper address so they can be evaluated correctly instead of immediately excluded.

    1. I filed a Freedom of Information Act (FOIA) request for the analysis performed by NCUA's Office of Chief Economist. NCUA denied my FOIA request in a July 10 letter.



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