The American Bankers Association urged the National Credit Union Administration to withdraw or significantly revise its "seriously flawed" proposals to its chartering and field of membership rules regarding federal community credit unions.
In a letter to NCUA Secretary of the Board Gerard Poliquin, American Bankers Association Senior Director for Banking Policy Justin Underwood wrote that the NCUA made an "inferential leap" that is "unreasonable and unlawful" when it proposed an amendment that would define a combined statistical area, or CSA, as a single local community as long as the chosen area has a population of 2.5 million people or fewer.
Underwood wrote that the U.S. Court of Appeals for the District of Columbia Circuit has not issued its mandate on the matter, which means that the U.S. District Court for the District of Columbia's decision remains in effect.
"It would be inappropriate for the board to reissue a rule that the district court held unlawful in a decision that has not been vacated," Underwood wrote.
The banking group also criticized the NCUA proposal to offer further explanation of its decision to remove a credit union's requirement to serve the "core" of a core-based statistical area, as it believes the NCUA should plainly state that credit unions have a special mission to serve people of modest means.
The association suggested that the NCUA require credit unions to submit sufficient data to demonstrate that its decision to exclude the urban core of a core-based statistical area will advance, rather than undermine, the goal of providing financial services to people of modest means.