NCUA will count active-duty military personnel in determining a credit union’s ‘low-income’ status

A change in methodology, announced Thursday, that captures the APO and FPO addresses of active-duty military personnel means those individuals’ incomes will now be included in the federal credit union regulator’s analysis of whether a credit union, such as the world’s largest, is eligible for the agency’s “low-income” designation.

Some of the benefits to credit unions of having the National Credit Union Administration’s (NCUA) “low-income” designation is an exemption from the statutory cap on member business lending, eligibility for grants and loans from the Community Development Revolving Loan Fund, the ability to accept deposits from non-members, and the authorization to obtain supplemental capital, the agency said.

Navy Federal, with its $125.6 billion in assets and 9.2 million members, has a military membership and, according to the NCUA’s online (and searchable) database, is not designated as low-income. Navy is one of 25 “active” federal credit unions that serve military or primarily military common bond memberships that lack this designation. (“Common bond” defines the type of membership a credit union may serve.) Another 35 such credit unions have it now, the data shows.

“At the NCUA, we’re always looking for ways to foster greater financial inclusion, accessibility, and opportunity for all Americans, which I consider to be the civil rights issue of our time,” according to a statement by NCUA Chairman Rodney Hood included in Thursday’s release. “This is a great step in being more inclusive when it comes to the members of the military. Because so many military members are just getting started, they may not have much experience in working with financial institutions, at least not yet. Currently, the NCUA encourages higher education by counting students in our methodology, and under my direction, the agency has determined we can encourage military service in a similar way.”

To qualify as a low-income credit union, a majority of the credit union’s membership must meet certain low-income thresholds, based on data from the Census Bureau and requirements outlined in the NCUA rules and regulations. The agency’s assessment tool geocodes the incomes of members based on their addresses; before Thursday’s announced change, only physical street addresses were included, and APO (Army/Air Post Office) or FPO (Fleet Post Office) addresses were omitted.

The agency announced the change in methodology against the backdrop of National Military Appreciation Month. It did not detail the specific action taken to effect the revision.

An upcoming Letter to Credit Unions will provide more information on the revised methodology, the agency said. Meanwhile, it said credit unions should contact the NCUA’s Office of Credit Union Resources and Expansion at or 703.518.1150 for additional information about the low-income designation.

NCUA Changes Low-Income Designation to Include Military Personnel in Calculation