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ABA Complains Proposed Sponsor Expansion Creates Overly Broad FOM

The American Bankers Association (ABA) complained in a letter sent to the National Credit Union Administration (NCUA) that Thrivent FCU sponsor’s expansion of its common bond from Lutheran to all Christians would create a field of membership (FOM) that is overly broad. The sponsor, Thrivent Financial for Lutherans, is scheduled to vote in March whether to expand its common bond membership from Lutheran to Christian. The ABA worries that this would automatically expand Thrivent FCU’s field of membership to all Christians, which it feels is overly broad.

NCUA responded to the ABA’s complaint by referring to Interpretative Ruling and Policy Statement 08-02, Section, III.A.2, which requires a federal credit union to submit a revised charter for approval prior to serving members of the expanded association. Following this requirement, Thrivent FCU would be required to gain NCUA approval before it could serve other Christian groups as part of an expanded field of membership.