Q: What about if an underserved area doesn’t pass the Depository Institution test due to the only facility within the area is the credit unions that is requesting to add the area? The credit union is required to have a facility within the area, but is disqualifying itself.
A: To address situations like this, the new rule now provides two alternative methods, as outlined below.
CFPB-designated “underserved county,” and
An analysis that relies on NCUA or another federal banking agency’s data to reflect the proposed area is underserved by other financial institutions