On Compliance: A new era dawns for community fields of membership

Recent updates to the National Credit Union Administration’s Chartering and Field of Membership Manual have the potential to revolutionize community chartering for federal credit unions, especially those that are based in the 29 metro regions in the United States that have a total population of more than 2.5 million.

On July 30, the NCUA Board issued a final rule authorizing FCUs to apply for community field of membership expansions for contiguous portions of “combined statistical areas”—the Office of Management and Budget’s largest type of core-based geographic statistical area based on patterns of local economic and social ties—that have a population of up to 2.5 million.

CSAs are groupings of smaller core-based statistical areas—such as metropolitan statistical areas or micropolitan statistical areas—centered on cities or large towns. Under the new rule, FCUs will not be required to serve a CSA’s “urban core” (i.e. its largest city) or the urban core of a large metropolitan statistical area that is not part of a CSA so long as it can demonstrate that it did not choose its geographic area with the intent to exclude low- and moderate-income individuals.

The Washington-Baltimore-Arlington, DC-MD-VA-WV-PA combined statistical area, for example, is the fourth most populous CSA with a total population of approximately 9.8 million people that includes seven smaller core-based statistical areas. It has Washington, D.C., as its urban core but also includes Baltimore and many smaller cities, as well as suburban, exurbanand rural areas in Maryland, Virginia, West Virginia and Pennsylvania. The new rule would allow an FCU to serve any contiguous portion of this area that has total a population of up to 2.5 million without the FCU having to provide additional evidence demonstrating that the proposed expanded field of membership is a local community.

 

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