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ABA: The American Bankers Association

ABA Statement on D.C. Circuit Court of Appeals Field of Membership Ruling

“We are pleased that the D.C. Circuit recognized the potential redlining risks that are created when credit unions try to exclude the urban core from their communities. We agree with the court’s warning that this ‘gerrymandering’ may disenfranchise poor and minority suburban residents by making it difficult for them to receive adequate financial services, and find it concerning that NCUA would actually propose a regulatory ‘license’ to do such a thing. At the same time, we are disappointed the court ruled that rural districts may be large and cross state lines. We further disagree with the court’s reasoning that a local community may be larger than a county, but are pleased by the court’s ruling that ABA is free to bring an as-applied challenge to ‘local communities’ that exceed NCUA’s authority, as we have done successfully in Utah and Pennsylvania. The court affirmed the basic principle that NCUA approval of field of membership expansions is not limitless. 

“We will review the ruling in detail as we determine our next steps to ensure NCUA doesn’t violate the expansion parameters set by Congress.”


About the American Bankers Association

The American Bankers Association is the voice of the nation’s $22.5 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $18 trillion in deposits and extend nearly $11 trillion in loans.

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