Legal opinion: Federal credit union can serve those who share core belief, practices with its membership group

A federal credit union chartered to serve Anabaptists and Mennonites is also permitted under the Federal Credit Union (FCU) Act to serve “individuals who share a core doctrinal belief and set of practices with those communities,” the federal regulator of credit unions said in a recent legal opinion letter.

“The Anabaptist concept of Christian stewardship is a distinctive aspect of Anabaptism (of which the Mennonites are one denomination) that requires practitioners to ‘live simply, practice mutual aid with the church, uphold economic justice, and give generously and cheerfully,’” Michael J. McKenna of the National Credit Union Administration (NCUA) wrote in the March 9 letter. “Individuals who share this core doctrinal belief have a significant and meaningful affinity with other members of the Anabaptist tradition, and we believe that such an FOM [field of membership] is a valid associational common bond.”

The FCU Act requires that membership in a credit union be based on a “common bond”; among the types of common bond allowed is an associational common bond. McKenna notes that religious organizations, including churches or groups of related churches, “are recognized associations within the meaning of the FOM rules and are automatically approved as satisfying the associational common bond requirements of the FCU Act.”

NCUA Legal Opinion Letter 17-1219