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Emerging Issues

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On June 17, 2014, our office responded to the NCUA’s request for comments concerning its Proposed Rule Regarding Associational Common Bond Field of Membership requirements for Federal Credit Unions.  Our comments can be found on the NCUA’s website here. SW&M commented on the potential application of "quality assurance reviews," the potential for ambiguity in the Proposed Rule to result in inconsistent application and overreaching, and aspects of the Associational Common Bond rules and rules regarding "service areas" which result in FOM rules not applying to a number of ways modern associations are organized.