Federal Credit Unions and Underserved Area Expansions

The NCUA issued Letter to Federal Credit Unions 21-FCU-03 stating that “any federal credit union with a multiple common bond field of membership may include in its field of membership, without regard to location, underserved communities as defined by the Federal Credit Union Act. To promote greater financial inclusion and strengthen communities, the NCUA encourages such credit unions to expand their service to underserved areas.

Expanding into underserved areas can also help diversify membership and increase a credit union’s lending opportunities. Adding an underserved area to a federal credit union’s field of membership does not change the nature of a credit union’s charter. A multiple common bond federal credit union may add additional groups under the NCUA’s multiple common bond expansion options after being approved to expand service to an underserved area.

The NCUA’s Chartering and Field of Membership Manual describes how a federal credit union can apply for approval to provide service to an underserved community. The process includes developing and submitting a business plan that specifies how the credit union will serve an underserved community. To encourage credit union expansion in underserved areas, the NCUA has created detailed guidance on how to create a business plan, and a pro forma financial statement template.

If you need any help, let us know.


Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.

Leave a Reply

Your email address will not be published. Required fields are marked *