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Administrative Law Keyed to Breyer
National Credit Union Administration v. First National Bank & Trust Co.
Citation:
522 U.S. 479 (1998)Facts
The Federal Credit Union Act (FCUA) of 1934 limits federal credit union membership to “groups having a common bond of occupation or association, or to groups within a well-defined neighborhood, community, or rural district.” Until 1982, the NCUA interpreted this provision to require that all members of an occupationally defined credit union share the same common bond. In 1982, the NCUA changed its interpretation to allow multiple unrelated employer groups to join a single credit union, with each group having its own common bond. Under this new interpretation, AT&T Family Federal Credit Union expanded its membership to include employees from unrelated companies. Five banks and the American Bankers Association challenged the NCUA’s approval of these charter amendments, claiming competitive injury because the NCUA’s interpretation allowed credit unions to serve customers who would otherwise use banking services from commercial banks.
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