Comment from American Bankers Association

American Bankers AssociationOpposeTrade association
Summary: The American Bankers Association (ABA) opposes the proposed rule because it weakens the statutory common bond requirement for federal credit unions by replacing clear boundaries with discretionary evaluations. They argue that the change creates uncertainty and allows for the expansion of credit union membership to include large commercial customer bases, which they believe undermines the legal and tax status of credit unions.
See attached file

View on Regulations.gov