Regarding nonmember deposits – “We thank NCUA for retaining the $3 million alternative cap in its final public unit and nonmember shares rule. As stated in our comment letter to the agency, we believe that removing the alternative limit could have harmed several credit unions that currently use the $3 million alternative cap, mostly small institutions, so this is a welcome change for them. – Elizabeth Eurgubian, Deputy Chief Advocacy Officer & Sr Counsel
Regarding field of membership – “Today’s proposal is consistent with Chairman Hood’s stated approach to implementing the D.C. Circuit Court of Appeal’s ruling, and we thank the agency for moving quickly to address this issue. We have long supported NCUA using the authority granted by Congress to ensure credit unions are able to serve members throughout the country, and look forward to sharing our feedback with NCUA.” – Elizabeth Eurgubian, Deputy Chief Advocacy Officer & Sr Counsel