The credit union lobby’s newly minted leader recently unveiled his strategy to defend the industry’s federal tax exemption: tout their 144 million members to every member of Congress, each of whom has credit union constituents. Historically, this well-worn path has served credit unions well.
While there is certainly strength in numbers, this approach highlights credit unions’ tenuous position as lawmakers increasingly question their activities.
Credit unions were established by Congress over 90 years ago to serve those of modest means with a common bond, like municipal employees in a particular city. Even though their membership has grown far beyond congressional intent, expansion remains the industry’s top priority.
And the new head of the so-called “movement” has an audacious membership goal: “The rest of America…and that’s a huge opportunity.”
For decades, credit union field of membership requirements limited potential membership to a specific group of individuals within a given community. That was by design and aligned with the credit union mission and structure, the very basis of the tax exemption; however, the Credit Union Membership Access Act (CUMAA) of 1998 and subsequent actions taken by the National Credit Union Administration (NCUA) have eliminated any vestige of the cooperative spirit.
This unchecked expansion comes with many risks. In addition to the many billions of dollars in taxes that credit unions are exempt from paying, the growth of the industry well beyond Congress’s original intent raises questions about whether credit unions are subject to appropriate regulatory oversight and accountability and whether they are truly benefiting the communities they were established to serve.
Since 1998, systemwide assets have nearly doubled, a boon for credit union executives and their lobbyists. Other industry and NCUA initiatives have continued the industry’s expansion efforts.
At an NCUA Board briefing last fall, the NCUA’s Office of Credit Union Resources and Expansion (CURE) provided a “New Charter and Field of Membership Update.” For the unindoctrinated, CURE’s primary mission is to facilitate credit union expansion.
According to the presentation, CURE goes above and beyond to help credit unions achieve that goal. Ten months into 2024, the NCUA approved 7,707 field of membership expansions. An overwhelming majority of the requests – 94% – were submitted through NCUA’s Consumer Access Processing and Reporting Information System (CAPRIS), a portal that enables multiple common bond credit unions to quickly “add all occupational and associational groups of any size” to their fields of membership.
Although the makeup of the NCUA’s board remains in flux, it will host an off the record Strategic Plan Town Hall with credit union stakeholders – closed to the press, of course – to generate “ideas on how the NCUA can strengthen credit unions and lessen burdensome rules.” Based on a trade group’s August 2025 letter to the NCUA, recommendations regarding charter and field of membership changes will be front and center.
The $2.37 trillion credit union industry provides an interesting case study for policymakers: since Congress last organized a hearing on the credit union tax exemption in 2005, these not-for-profit financial cooperatives have evolved into multibillion-dollar institutions that prioritize growth over service. Credit union oversight is long overdue, and Congress must convene a hearing this fall. Waiting another 20 years is not an option.
