Field of membershipis an issue which has concerned me for some time, ever since Iserved on the board of one of my local credit unions, and laterwhen I shepherded modernization of Oregon's FOM rules through itslegislature. FOM is an issue which I believe we can startaddressing through regulation, and continue to work on throughstatutory changes. These changes can help federal credit unionsgrow and serve more Americans, especially those of modestmeans.

In the decade and a half since the passage of the Credit UnionMembership Access Act of 1998, online and internet banking haveexploded, the financial services industry has consolidated and manystates have modernized their state charters. Unfortunately,the federal charter has not kept up with thesechanges.

It needs to be modernized, and that is something you and I canboth work on.

At the NCUA, we have a responsibility to make sure that we fullyuse the authority we have under CUMAA to help credit unionsstrengthen their bottom lines and be able to serve moremembers. That's why I am pleased that the agency has formedan internal working group to review our FOM regulations.

Our working group will consult with credit unions and otherinterest parties on how we can, under our existing authority,improve federal FOM rules. I believe there are a number of changeswe can make to streamline our existing rules and expand access tocredit union services for American families.

Among them are at least five changes that could have significantimpact:

1. Allow credit unions converting from single or multiple commonbonds to community charters to continue serving select employergroups, even if they are located outside the new community charterboundaries;
2. Permit the addition of adjacent areas to community charterswithout requiring them to be in a Census Bureau “Core-BasedStatistical Area”. And parenthetically, I would challenge anyof you to tell me what the borders are of the CBSA you livein. Almost no one outside the Census Bureau knows what theyare or considers them relevant to the markets credit unions seek toserve.
3. Eliminate the current requirement that a community charterserve the “core area” of a CBSA. Again, I would challengemost people to identify what the core area is of the community theylive or work in.
4. Revise and simplify the processing for determining that an areais underserved and thus eligible to be added to the FOM of acommunity charter.
5. Allow active-duty military personnel and their families toautomatically qualify as low-income households.

I invite the credit union community to send me their additionalideas of how the regulations can be streamlined and improved,within the confines of existing law.

It is also clear to me that there are FOM changes that arenecessary, that go beyond NCUA's authority under existinglaw. We need Congress to pass changes in the statute. We know that may not be easy in the current political environment,but past changes were enacted on a bipartisan basis, and we wouldhope that future changes could be as well.

Enacting statutory changes will not be easy, and it will requireall of us, both the regulator and regulated, to work together toovercome other groups who have a vested interest in maintaining thestatus quo.

It frankly is not helpful when groups such as NAFCU suggest, asNAFCU did this week in an op-ed accusing us of hiding behind thelaw (NCUA and FOM: Hiding Behind the Law, Jan. 5 CUTimes), thatthe NCUA is responsible for lack of action on CapitolHill. This would be like the agency suggesting that lack ofaction on Capitol Hill is due to NAFCU's ineffectiveness inlobbying on the Hill. It is disingenuous at best for NAFCU tosuggest that the agency is “Hiding Behind the Law” whenthey know that the specific changes they request ALL requirestatutory changes and are not within our authority to grant. The agency isn't hiding behind the law, we are implementing thelaws the Congress has passed, which is our responsibility.

Finger-pointing benefits no one, when we need to be workingtogether, and especially when they know, or should know, that theNCUA's most recent testimony to the Senate Banking Committee onSept. 16 included one of the specific FOM changes NAFCU now says itwants.

So I call upon the credit union community to put asidefinger-pointing, and come up to Capitol Hill in 2015 and join theNCUA in calling for enactment of legislation to enable creditunions to compete in today's increasingly complex financial marketsand to serve more American families, especially those of modestmeans.

Rick Metsger is vice chairman of the NCUA. The above wastaken from Metsger's prepared remarks delivered Jan. 8 at the NoVaChapter of the Virginia Credit Union League.