Metsger Advocates Greater FOM Flexibility

In a speech to credit union officials of the Northern Virginia Chapter of the Virginia Credit Union League, National Credit Union Administration (NCUA) Vice-Chairman Rick Metsger called for changes in regulations and in law to give federal credit unions greater flexibility in defining their fields of membership (FOM).

Regulatory FOM changes that Metsger would like to see address, include:

• Allowing credit unions converting from single or multiple common bonds to community charters to continue serving select employer groups even if they are located outside the new community charter boundaries;
• Permitting the addition of adjacent areas to community charters without requiring them to be Core-Based Statistical Area;
• Eliminating the requirement that a community charter be based on a core area of a Core-Based Statistical Area;
• Revising and simplifying the process for determining that an area is “underserved”; and
• Allowing active-duty military personnel and their families to automatically qualify as low-income households.

Legislative changes advocated by Metsger would allow all credit unions, not just multiple common-bond charters, to add underserved areas; would simplify the “facilities” test for determining if an area is underserved, and would give community-based federal credit unions the option to structure their fields of membership in accordance with law of the state in which they operate.

I will be very interested in seeing what tortured legal analysis that NCUA will come up with to justify that these proposed regulatory changes are consistent with the statute.

Read the press release.