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Emerging Issues

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Federal Multiple Common Bond Amendments

In the NCUA Field of Membership (FOM) rules, effective on February 6, 2017, multiple common bond federal credit unions (FCUs) were provided with the ability to serve employees of contractors to their Select Employee Groups (SEGs), provided the contractors have a strong dependency relationship with the SEG. We had originally assumed that such authority may be automatic. However, in a recent webinar and published FAQ, the NCUA has said that FCUs will need to request housekeeping amendments to their charters to effectuate this change. We believe this is something all multiple common bond FCUs should request to be added to their charters. FCUs with TIP (trade, industry or profession) and other single occupational common bond charters may also wish to consider asking whether such an amendment will be possible. The language to be included in the charter amendment request is included in the NCUA’s recently published FOM FAQs, and will be included in our upcoming Client Pool with request materials.