WASHINGTON–In separate comment letters, DCUC and America’s Credit Unions have expressed support for proposals related to field of membership and indirect auto lending, respectively.
In its new comment letter to NCUA, the Defense Credit Union Council told the agency that it supports its proposed rulemaking to amend associational common bond requirements for chartering and field of membership.
As the CU Daily reported earlier, the proposal would amend language in NCUA’s Chartering and Field of Membership Manual to clarify that requiring the purchase of a product or service as a condition of membership does not automatically disqualify an otherwise legitimate association from the Federal Credit Union Act’s associational common bond provisions.
Instead, in reviewing applications to determine eligibility, the NCUA would consider the entirety of the circumstances such as the group’s structure, scope and degree of its activities, and other operational factors to conclude whether its relationship with its members is primarily or incidentally a client-customer relationship.
Reflects ‘Statutory Intent’
DCUC said it supports the NCUA’s proposed change because it more accurately reflects the statutory intent of the FCUA and the revised example better clarifies the requirements for an associational common bond. This amendment will help many credit unions navigate the field of membership requirements.
“DCUC appreciates the NCUA Board’s efforts to modernize and streamline the agency’s regulatory requirements while preserving operational flexibility for credit unions,” the letter states. “We look forward to continuing to work with the NCUA on future initiatives that enhance regulatory clarity, improve operational flexibility, and reduce unnecessary compliance burden.”
America’s CUs Supports Indirect Lending Change
Separately, in a comment letter, America’s Credit Unions told NCUA its proposed rule to clarify third party servicing of indirect vehicle loans would “provide federal credit unions with needed change and flexibility, offering parity with many state-chartered credit unions.”
The trade group said it supports removing what it called an overly prescriptive, one-size-fits-all requirement that limits credit unions’ ability to structure their own indirect lending programs.
The proposal is outlined in the eighth round of the NCUA Deregulation Project, addressing Section 12 CFR Part 701.21(h), Third-Party Servicing of Indirect Vehicle Loans. It is intended to reduce administrative costs and compliance complexity, enabling credit unions to serve their members more efficiently.
“Removing the prescriptive limits tied to third party servicing of indirect vehicle loans would help restore regulatory parity, allow FCUs to align their policies more closely with market realities, and reinforce the principle that credit union boards and management are best positioned to oversee these programs,” the letter states. “Doing so would create a more level playing field for all credit unions seeking to participate in these programs.”
