Chartering and Field of Membership

On behalf of its member credit unions, the Cooperative Credit Union Association, Inc. ("Association") appreciates the opportunity to comment on the National Credit Union Administration's (NCUA) proposed rule to amend the agency's Chartering and Field of Membership Manual. The Association is the state trade association representing approximately 200 state and federally-chartered credit unions located in the states of Delaware, Massachusetts, New Hampshire, and Rhode Island, which further serve over 3.6 million consumer members. The Association has developed these comments in consultation with our members. The Association's High-Level Comments: •The Association supports this proposal, including streamlining the underserved area expansion process and better harmonizing it with updated Community Development Financial Institution Fund rules. We urge the Board to finalize the rule as proposed. •The Association strongly supports the NCUA Board's proposal to allow federal credit unions (FCUs) to add underserved areas without regard to geographic location. •We support the proposed simplified business and marketing plans for community field of membership conversions and expansions, as well as the proposal to eliminate this requirement for state-chartered community credit unions converting to FCUs. •We strongly support the proposal to allow members of affinity groups based within a community credit union's geographic community to join the credit union, as well as to allow family members of deceased members to join. •We urge the Board to clarify that states—like Rhode Island—which fall entirely within a Census Bureau Combined Statistical Area can be community fields of membership.