NCUA's Proposal to Improve Associational Field of Membership
About this episode
The episode discusses NCUA's proposed changes to the associational common bond rules to enhance access to financial services.
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA Proposes to Loosen Associational Common Bond Rules The NCUA Board has issued a proposed rule that would amend the associational common bond provisions of its Chartering and Field of Membership Manual. Comments are due by June 8, 2026. What NCUA is proposing: Eliminate the automatic bar that currently disqualifies an associational group from FCU field of membership eligibility when the group requires purchasing a product or service as a condition of membership. Replace the bright-line rule with a totality of the circumstances review, looking at the group's structure, scope, degree of activities, and other operational factors. Clarify that a client-customer relationship can exist, even as a condition of membership, as long as it remains incidental to the group's overall purpose and activities. Use an example of a fraternal association that requires insurance purchase - under the proposal, this would no longer be automatically disqualifying. Why the change: The Board believes the automatic bar goes beyond what the FCU Act actually requires. Neither the FCU Act nor the Credit Union Membership Access Act of 1998…
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