FOM- The Clock is Almost Up; MLA Database Deadline on Monday
Written by Alicia Nealon, Director of Regulatory Affairs
With just over a week before the February 8th comment deadline for NCUA's Field of Membership (FOM) proposal, NAFCU wanted to remind you that we have put together Talking Points to assist as you put your comment letters together.
The bankers continue their campaign against NCUA's proposal. While NAFCU is busy in Washington disproving the bankers' misinformed attacks, it's vital that credit unions continue to weigh in on this proposal to ensure that NCUA knows how important this relief will be to our industry and the millions of consumers who want safe and sound credit union services.
NAFCU believes NCUA's proposal will help many credit unions reach more potential members who want and need affordable financial services, and I encourage you to write a comment letter to NCUA explaining how the proposal will provide much needed relief to your credit union and membership.
NAFCU has drafted individual templates for Community, Multiple Common Bond and TIP Charters. While the Talking Points should be colored with the views and opinions of your credit union, NAFCU has listed a number of helpful arguments broken down by topic. For example, the Talking Points detail how the proposal will help Community Charters expand into adjacent areas within the confines of the Federal Credit Union Act. We have also blogged about various aspects of the proposal, including posts individual to Community, Multiple Common Bond and TIP Charters.
Thank you to all who have written comment letters to NCUA. For those that are still thinking about sending comments to the agency, NAFCU cannot stress enough that it is pivotal that the entire credit union industry weigh-in. Your insight is valuable to the agency. The thoughts and input you express will ultimately lead to better FOM requirements for credit unions.
As you consider writing an FOM comment letter, be sure to take a look at NAFCU's Regulatory Alert 15-EA-20, our Field of Membership Issue Page, or reach out to me directly (anealon@nafcu.org, 703-842-2266) with your thoughts.
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Another reminder - Monday, February 1 is the deadline to let the Defense Manpower Database Center (DMDC) know that your credit union is interested in directly connecting with their Military Lending Act database (discussed in this earlier blog post). NAFCU did join in a letter to DMDC asking to extend this deadline until March 1. Keep in mind that even without a direct connection, the database will allow credit unions to submit up to 50 large batch queries a day of up to 250,000 individual checks, but with a 24 hour turn around. However, the direct connection will allow some credit unions to connect directly to this database which may be particularly helpful to those credit unions expecting to run a high volume of covered borrower checks and/or require responses on large batches in less than 24 hours. If your credit union wants to express interest, the email address to reach out to DoD is dodhr.dodc-mb.dmdc.mbx.mla@mail.mil. Feel free to reach out directly to Brandy Bruyere, NAFCU's Director of Regulatory Compliance (bbruyere@nafcu.org) with questions.
One last note for today - the clock is ticking for you or someone else in your credit union to attend NAFCU's 2016 Regulatory Compliance School. There are only 27 seats left! Attending School is not only a great chance to learn the rules of the regulatory road, but it is also a wonderful opportunity to propel your career as a compliance leader in your credit union and community. Because seats are running out, I encourage you to check out the agenda and register today!