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NCUA Releases Guidance on Low-Income Designations: Qualification of Military Personnel

Thursday, May 28, 2020  
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The NCUA has just released its guidance on Low-Income Designation and the inclusion of all military personnel.

The NCUA’s primary method will be to total the number of members with an APO or FPO mailing address in the AIRES download file. These members will be included in the total number of members served, and a percentage will be reflected as low-income members, consistent with the Office of Chief Economist’s analysis, in determining whether the majority of the credit union’s members are low-income. in the AIRES download file. Please note: This change to the low-income designation methodology will be handled by the NCUA — it does not result in any additional burden or requirements for credit unions.

Because the NCUA does not generally retain member address data after analyzing the AIRES download, the new methodology will be applied from this date forward. If your credit union does not want to wait until the next normal cycle for this to occur, please contact the Office of Credit Union Resources and Expansion (CURE) to arrange the submission of a new AIRES download file.

For those credit unions serving military members without an APO/FPO address, additional options include, but are not limited to, a credit union submitting the following information to CURE:

·    A list identifying members who are active-duty military personnel. For this option, no additional member-specific information (such as incomes, paygrades, ranks, etc.) is necessary. The NCUA will factor these members into the low-income designation analysis similar to members with an APO or FPO mailing address.

·    Granular data for military members, including active-duty and members of the Reserve and the National Guard. Data could include actual income, paygrade, years of service, or rank of its military members.

·    The credit union can conduct and provide to the agency for evaluation any relevant analysis that demonstrates that all or some portion of its military membership, including active-duty and members of the Reserve and the National Guard, qualify as low-income. To ensure efficiency whenever possible, the NCUA recommends discussing a proposed methodology with CURE before undertaking such an analysis.

DCUC would like to thank Chairman Rodney Hood for his steadfast support in getting this initiative approved, followed by providing implementing guidance to the field.

His statement says it all: “The NCUA is always seeking opportunities to foster greater financial inclusion, accessibility, and opportunity for all Americans. To that end, the NCUA’s goal in improving the low-income designation methodology is to ensure full financial inclusion for the men and women serving in our nation’s military. They keep us safe, and our commitment is to keep their funds safe.”

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