Newsroom

May 19, 2015

NAFCU at NCUA on RBC2, FOM

NAFCU discussed credit union concerns related to NCUA's risk-based capital proposal and field-of-membership rules during a meeting at NCUA Monday with Mike Radway, senior policy advisor to board Vice Chairman Rick Metsger.

During the meeting, NAFCU Director of Regulatory Affairs Alicia Nealon and Regulatory Affairs Counsel Kavitha Subramanian focused on members' input to the association on RBC2 and the recommendations produced recently by NAFCU's FOM Task Force.

The task force, with representatives from more than 50 member credit unions of various asset sizes and charter types, provided recommendations for streamlining chartering and FOM expansion procedures and to remove non-statutory constraints.

The task force urged, among other things:

  • removing non-statutory requirements that impose geographic limitations on FOM chartering and expansion;
  • updates of the Chartering and FOM Manual, which has not been changed since 2003, to reflect the current process;
  • deadlines for NCUA to respond to FOM amendment requests;
  • more transparency in the decision-making process regarding FOM-related applications, with a formal notification process and regular status updates about applications;
  • removal of the arbitrary 2.5 million population cap for "well-defined local communities," as it is not mandated by the Federal Credit Union Act; and
  • revising the "rural district" definition to allow deserving communities to qualify.

FOM changes are a major focus of NAFCU's "Top Ten Regulations to Eliminate or Amend" and its "Five Point Plan for Regulatory Relief."