ABA Comment Letter on NCUA's Proposal on Shared Facility Requirements

Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428

Ladies and Gentlemen:

The American Bankers Association (ABA) appreciates the opportunity to provide comments to the National Credit Union Administration (NCUA) on a proposed rule (Proposal) that would amend its chartering and field of membership manual (Chartering Manual) related to service facilities for multiple common bond (MCB) federal credit unions (FCUs). The proposal would amend the Chartering Manual so that the facilities of any shared branch network in which an FCU participates would qualify as a “service facility” (i.e., a place where membership account and/or loan activity is conducted). The Proposal thus would remove the service facility ownership requirement and allow a leased (as opposed to owned) automated teller machine (ATM) and other non-owned electronic facilities to satisfy the statutory geographic proximity and physical presence requirements for a MCB FCU field of membership expansion. The Proposal would also apply a loosened service facility definition to select groups and to underserved areas, the latter of which currently enjoy broader consumer services under a more rigorous definition. As a result, the Proposal would enable significant field of membership expansion while diluting the physical presence of credit unions in the communities they are applying to serve.

Download the comment letter to read the full text.