Chartering and Field of Membership

GECU Federal Credit Union supports the proposed rule because it provides regulatory clarity by allowing the NCUA to evaluate associations based on their overall structure rather than automatically disqualifying those with product or service requirements. The credit union also requests that the NCUA provide additional guidance and illustrative examples to help clarify the distinction between incidental and commercial relationships.

The Illinois Credit Union League, a trade association representing over 190 credit unions, supports the NCUA's proposal to remove the automatic disqualification of associational groups that require the purchase of a product or service. They argue that evaluating the totality of an association's circumstances better aligns with statutory intent and provides necessary regulatory relief and flexibility.

The Cooperative Credit Union Association, Inc. supports the NCUA's proposal to eliminate the prohibition on federal credit union associational common bonds for associations that require a product or service purchase. They urge the Board to clarify that consumer-owned co-operatives, including credit unions, have "incidental client-customer relationships" similar to the insurance example provided in the proposal.

The Wisconsin Credit Union League supports the NCUA's proposal to amend associational common bond provisions, arguing that it provides credit unions with greater flexibility to serve diverse communities. They contend that the shift toward a case-by-case evaluation framework allows for a more tailored assessment of common bonds while maintaining robust supervisory oversight and consumer protections.

The Ohio Credit Union League (OCUL), representing Ohio's credit unions, supports the NCUA's proposal to remove the automatic disqualification of associational groups that require the purchase of a product or service as a condition of membership. They argue that the change alleviates an unnecessary regulatory burden and provides relief to credit unions of all sizes without compromising the integrity of the field-of-membership requirements.

TruStage, a provider of financial products and services to unions, supports the NCUA's proposed amendment to the associational common bond provisions. They argue that the amendment provides necessary regulatory clarity by allowing the NCUA to evaluate the totality of an association's activities rather than automatically disqualifying them based on product-purchasing requirements.

The Cornerstone Credit Union League, a trade association representing nearly 600 credit unions, supports the proposed amendments to 12 C.F.R. 701. They argue that removing the automatic disqualification of certain associational groups will provide regulatory relief and improve operational efficiency without compromising the intent of field-of-membership rules.

Rick Mumm expresses full support for the proposed rule but argues that it is somewhat superficial and fails to resolve underlying ambiguities in the Chartering Manual. He recommends adding clear definitions for "client-customer relationship" and "primarily," and suggests replacing the Knights of Columbus as the example of a qualifying single common association.