DCUC is excited to share that in a press release earlier today, NCUA announced a change in 12 CFR § 701.34 (2), adding a provision to allow military families using an APO/FPO address to be included in calculations for the Low-Income Credit Union (LICU) designation.
To qualify as a LICU, a majority of a credit union’s membership must meet low-income thresholds defined in the NCUA Rules and Regulations. In general, for members to meet the low-income thresholds, their income must be at or below 80 percent of comparable median family incomes or median earnings for individuals in their geographic area, their state, or the nation.
A credit union with a low-income designation has access to many benefits that allow them to better serve their membership, especially those that may be traditionally un- or under-banked. Benefits include the ability to:
- Raise supplemental capital that counts toward net worth;
- Accept non-member deposits from any source;
- Make member business loans beyond the statutory cap;
- Apply for grants and low-interest loans from the NCUA’s Community Development Revolving Loan Fund.
By allowing credit unions to include APO/FPO addresses in this calculation, it may give defense credit unions who are close to the 50% + 1 threshold the boost they need to qualify.
“This is great news!” stated DCUC President/CEO Anthony Hernandez. “It makes sense since military members enter the service right after high school or college, and the current definition of ‘low-income members’ includes credit union members enrolled as students in a college, university, high school, or vocational school. Military members are no different in terms of income levels under the established criteria in section 701.34 (2).”
While military life is different in many ways, it is DCUC’s mission to make sure they are counted and included, especially when talking about serving vulnerable populations and the un- and under-served.
DCUC raised this subject during its October 2019 Military Advocacy Committee meeting and worked with Global Credit Union and the Northwest Credit Union Association on advocacy measures including meetings with NCUA Board Members and staff. The idea gained additional momentum after it was discussed in February during DCUC’s Defense Matters 2020 until being overcome by COVID-19 events. DCUC stressed the importance again in a letter to NCUA dated April 8, 2020.
Hernandez noted that this change comes as the country recognizes the contributions and sacrifices of service members during National Military Appreciation Month and is well-timed to help with economic recovery efforts as a result of COVID-19.
“I would like to thank NCUA for its ongoing support for our nation’s military and their families,” stated Hernandez. “This rule change will allow more military and veteran members to participate in our economic recovery.”