Q: Can a credit union, on behalf of the group, state the group doesn’t have the desire or ability to form its own credit union as required on NCUA Form 4015A or 4015, or must this information be in the group letter?
A: No. The group must address why the formation of a separate credit union for the group is not practical. A credit union cannot address or document this requirement for the group. If the group size is between 3,000 and 4,999, the group’s letter needs to state it does not have a desire or an interest in forming its own credit union. If the group size is 5,000 or more, the group’s letter needs to continue to address the criteria outlined in Chapter 2, Section IV.B.2 of NCUA’s Chartering and Field of Membership Manual.