Once I was stopped in Hungry and fined for transferring subways on the same platform by a severe looking official and told: “rules are rules. I don’t write them I just follow them.” The NCUA can be a little like that. Luckily we have Jim as our first layer of contact with the governing body of Credit Unions to guide us through the process. But, “rules are rules,” and sometimes what he asks for (to satisfy the NCUA) does not compute.
The first step in getting a credit union is to ask for pre-qualification. This means that the NCUA says essentially, “ok your request for opening a Credit Union makes sense to us, and there’s a decent chance of you getting a charter one day.” Brian told us that he knocked one of those letter off in 5 minutes, but we think that, post big bank induced financial meltdown, it will not be the case for us. We are seeing that we have to find our own way “through the looking glass world” a lot more than we thought. Jim was nice enough to review our pre-qualification letter before we “officially” submitted it, and he had lots of changes. For example, Census data must be of same year, so if you have 2010 data for New Brunswick and 2007 data for Highland Park (a suburb we want in our field of membership) you have to use 2000 census data because that is the last time the census published info on both. Ok…sure.
We find out that we could probably get a Field of Membership (those folks who can use your Credit Union), consisting of all Middlesex county NJ. That whole area has almost 800,000 people, but if we did that we could not get our low income designation, even though we are located in a low income area. We find out that there are three types of charters: Community – The area you are located in up to 1mm people, TIPS – Trade or Industry that you wish to serve – like anyone in US that works for a Not for Profit (NFP), and Multiple Common-Bond – some combination of both. We would like a multiple common-bond of New Brunswick and people who work for an NFP, but we are told our CU is unlikely to be approved to start this way. Their view – not unreasonable, is the same as my professors as an undergrad: “Prove yourself young man.” Ok, so community charter it is.
They then ask us to identify the two communities we will serve: New Brunswick and Highland Park, NJ. We submit three maps highlighting New Brunswick and Highland Park. We mention that the whole towns are defined by their zip codes. We note the roads that join them. We show where they are in the whole county. We show all the demographic data. Now Jim tells us that we have to define the towns by essentially walking them like a surveyor noting landmarks – Cemetery to your left, Raritan River to your right. Whew – who knew? Hint for future Credit Unions just go to town hall and ask for a tax map of the community and note borders and landmarks in as much detail as possible. It will save you lots of trouble. If and when we get our pre-qualification approved we will post it on the blog.
More Alice through the looking glass to come….