Well-Defined Local Community or Rural District
Briefly describe how the proposed service area qualifies as well-defined local community or rural district. This includes presumptive communities (a single political jurisdiction or portion of one; combined statistical area or core-based statistical area or a portion of one that has a population at or below 2.5 million people; a rural district with a population of 1 million or less; and an area the NCUA previously determined is a local community).
When adding a bordering area that is not part of a presumptive community, provide compelling evidence that demonstrates interaction or common interests. For more information, see NCUA Letter to Federal Credit Unions 18-FCU-02, Requests to Serve a Well-Defined Local Community Using the Narrative Approach.
Presumptive community examples: The community is comprised of Scott County, IA, and Rock Island County, IL, a portion of the Davenport-Moline-Rock Island IA-IL Metropolitan Statistical Area.
Excluded Core Area
The NCUA defines a core-based statistical area’s “core” as the most populated county or named municipality in the area. If a presumptive community consists of a portion of a combined statistical area or core-based statistical area and does not include the core area, address why the core area was excluded. Provide data or examples to demonstrate the rationale for your business decision. The example provided is for illustrative purposes only; the actual reasons will depend on unique factors applicable to the area, the credit union’s resources, or the overall business strategy.
Example: ABC Federal Credit Union is requesting to exclude the core area because the principal city is overbanked, underpopulated by residents (mostly commercial), and is not distressed, as defined in the Chartering and Field of Membership Manual (underserved from poverty, unemployment, or median household income). This demonstrates that ABC FCU has not excluded the core in an attempt to illegally redline or discriminate. In addition, ABC FCU has included third party data to support these indicators. Note: Alternatively, the credit union can demonstrate that its resources are more effectively used by serving an area that does not include the core.
Include the most recent population estimate of the community. Cite the data source.
Example: The 2014-2018 American Community Survey five-year population estimates indicate the population of the community at 590,630.
Describe the geographic boundaries of the community the credit union will serve. A description could include the names of the political jurisdictions the area encompasses. Include a map, and if this is a community expansion request, ensure the map delineates the existing community served by the credit union and clearly shows the proposed addition.
- The community is comprised of two contiguous counties: Scott County, Iowa, and Rock Island County, Illinois.
- The community is a rural district comprised of the cities of Asbury and Dubuque in Dubuque County, Iowa, and East Dubuque in Jo Daviess County, Illinois.
Reasons for Community Charter Conversion or Expansion
Discuss management’s rationale for pursuing the community field of membership. Describe how the proposed conversion or expansion will improve member service, safety and soundness, adherence to the credit union’s business plan, or other factors. If your credit union is expanding to bring service to areas with limited financial services, provide an analysis demonstrating the community’s needs.
Example: ABC Federal Credit Union is requesting this conversion because our primary sponsor, XYZ Corporation, is downsizing. ABC management has determined that conversion to a community charter will provide more financial stability and long-term viability for the credit union.
Groups Outside Proposed Service Area
Identify all group(s) outside the community’s boundaries that are currently served by the credit union, including their location(s) and number of employees. Discuss management’s strategy for communicating with these group(s). This applies to potential members who would no longer be eligible for membership following a conversion to community charter. The credit union can continue to serve members of record.
Example: ZYX Corporation is located outside of the community’s boundaries. Upon approval of the conversion request, ABC Federal Credit Union will notify ZYX Corporation that the credit union can no longer accept new members from the company.
Products and Services
Summarize the key products and services that will benefit most residents of the community. Describe any new products or services the credit union will add, including any accompanying fees. Describe the audience for the key products and services.
Do not include products or services provided by a third-party vendor, such as investment or insurance services.
- ABC Federal Credit Union offers a suite of products and services to meet the various needs of the proposed community. These include share drafts, certificates, mortgage loans, safety deposit boxes, mobile and online account access, and credit and debit cards.
- ABC Federal Credit Union’s products and services are summarized in the table below:
|Product / Service||Description||Youth Under 16||All Members over age 16||Young Adults age 18-24||Adults age 25-59||Seniors age 60 and over||Underserved/ Low Income|
|Share Savings Account||Dividend-paying savings account with a minimum balance of $50 intended for the general population.||X||X||X||X||X|
|Kids Saving Club||This is a rewards savings program to teach our younger children to save by rewarding them for each deposit. This program also benefits low-income members with a
$5 minimum balance.
|Youth Savings Account||A savings program for children 12 years old and older that can be opened with a minimum of $5 and earns dividends from $10, which is advantageous for low income youth. This program promotes financial literacy.||X||X|
|Young Adult Program||Access to starter accounts and additional educational resources for young adults; first-time checking, debit, and auto loans are available along with a free financial literacy library.||X||X|
General Financial and Growth Projections, Including Narrative Assumptions
Attach the complete pro forma financial statements, including assumptions. Projections should include balance sheets and income statements for the first two years after the NCUA approves a conversion or expansion. Please include projections for membership and net loan losses for the same period. The NCUA has provided a financial statement template a credit union may use to support and illustrate the financial impact of expansion dependent on the population, geographic size, and demographic diversity of a community.
Please identify the time frame used for the base period for the projections and discuss the underlying assumptions for the projected growth in shares, loans, and members. Examples of factors applicants could use in developing underlying assumptions include a credit union’s historical trends, growth trends experienced during prior expansions, expectations developed from planned marketing initiatives, local economic patterns or consumer needs, or original forecasting research. These assumptions should be consistent with the goals and strategies outlined in the marketing plan.
Example: Historically, ABC Federal Credit Union has opened 20 new accounts per month. New members open accounts with an average of $500. With the conversion to community charter, ABC anticipates opening 25 new accounts monthly for the first year after conversion and 28 new accounts monthly in the second year after conversion. We project these accounts will have an average opening balance of $500. We project the loan-to-share ratio will remain stable at 80 percent. The financial projections are based on actual performance through June 30, 2022.
Financial Impact of Conversion or Expansion
Present the anticipated financial impact on the credit union, including the need for additional employees and fixed assets and the associated costs. These costs must be included in the pro forma financial statements. Include a discussion of the basis for the estimated costs and attach appropriate supporting documentation, if necessary. Management should address marketing expenses in the marketing budget and not in this section. (See the Marketing Budget Section below.)
Example: ABC Federal Credit Union will add a marketing manager and two customer service representatives to serve the proposed community. The annual cost is projected at $100,000 for salaries and benefits, based on our current salary structure. Additionally, ABC Federal Credit Union will purchase computer equipment for a one-time cost of $3,000 in the first year after conversion. This cost is based on previous purchases of similar equipment. These costs are included in the pro forma financial statements.
Branch Structure and Service Delivery
Describe the current and proposed office/branch structure. Include a general description of the location(s), parking availability, public transportation availability, drive-through service, lobby capacity, or any other service features illustrating community access. Include a map demonstrating the accessibility of the current and proposed service facilities and ATMs. The map should also show the political boundaries, major roads, and other pertinent information.
Describe service delivery options other than the credit union’s physical office(s) in the community. Your plan should describe how residents can join your credit union (online, in a branch, or other method) and how they can access services after joining. Alternative service delivery options may include shared branching, online access, mobile services, and non-credit- union-owned ATMs (with or without a fee).
Example: ABC Federal Credit Union has three offices in the proposed community. These offices are located at Main and Locust Streets in Davenport, Iowa; 53rd Street and Utica Ridge Road in Bettendorf, Iowa; and 41st Street and Avenue of the Cities in Moline, Illinois. The offices are all open from 8:30 a.m. to 5 p.m. Monday through Friday and 9 a.m. to 1 p.m. on Saturday. There are five teller stations at each location with lobby capacity for 25 members. The Davenport location has two drive-through lanes and parking for 30 vehicles. The Bettendorf and Moline locations each have one drive-through lane and parking for 20 vehicles. All three locations have surcharge-free ATMs. Members have access to an additional 25 surcharge-free ATMs in the proposed community. Residents can apply for membership online or at any of our three offices. Residents can also join the credit union and access many services online. ABC is part of a shared branching network. Members can deposit and withdraw funds at five shared branch locations in the community and an additional 150 locations nationwide.
A key component of a community charter conversion or expansion is a demonstrated ability and intent to serve the entire community. The written business and marketing plan should correlate with the federal credit union’s mission and discuss the general marketing strategy that management will follow. The implementation plan must be commensurate with the population, geographic size, and demographic diversity of the community. Provide supporting documentation, as necessary.
Address the media outlets and communication plan for marketing to the proposed community. Focus on marketing to residents in the community who are not currently members. Demonstrate how the marketing and outreach efforts will encompass all demographic segments of the community.
Example: ABC Federal Credit Union will advertise on the local network television affiliates. We will advertise on the local radio stations, which reach a variety of demographic audiences. The advertising will be structured to appeal to 18-35 year olds, 36-55 year olds, and residents age 55 and older.
Marketing to All Groups
Address marketing efforts to all demographic segments. Identify and address unique demographic segments in the plan, such as languages spoken, ethnicity, or age. Explain how the credit union will market to the underserved (economically distressed) areas of the proposed community. You do not need to provide a complete list of all demographics.
- Data obtained from the Community Development Financial Institutions Fund shows 23 census tracts in the proposed community are economically distressed. These tracts have 35 percent of the proposed community’s population. To meet the needs of these residents, ABC Federal Credit Union will use direct mail to promote our monthly financial literacy seminars. We will also promote our savings programs and free share draft and debit card programs.
- Census Bureau data show 25 percent of the population speaks Spanish as their primary or only language. To meet the needs of this demographic group, ABC Federal Credit Union has Spanish-speaking member service representatives at each office. Additionally, we have bilingual marketing materials and Spanish language “Your Insured Funds” brochures for these individuals.
- Census Bureau data show 20 percent of the community’s population is under age 18. ABC Federal Credit Union promotes its youth savings accounts that require just $5 to open and earn dividends. We will also work with schools in the community to provide financial literacy materials and training.
Outreach to Community-Based Organizations
Describe management’s plans to establish partnerships with community-based organizations (nonprofit organizations, churches, schools, and other groups operating in the community) to assist the credit union in its outreach efforts. Explain each organization’s function in the community and how the credit union will partner with the organization. The partnership should demonstrate an effort to extend credit union services to the economically distressed population within the community. Partnership with community-based organizations should be more than providing financial support.
Example: ABC Federal Credit Union will partner with the EFG association for community outreach. EFG association helps low-income residents with affordable housing and childcare services. Our partnership with the organization will enable the credit union to provide free financial counseling and training on creating a budget. We also teach residents about saving money and rebuilding credit. EFG association has an office in the community where we can conduct these events.
Provide marketing budget projections that confirm greater resources have been dedicated to reaching residents in the proposed community. Budget totals should correspond to the pro forma financial statements.
Example: The marketing budget will be $XX,XXX and $XX,XXX, respectively, for the first two years. Management will allocate specific expenditures as shown in the table below.
|Category||Year 1||Year 2|
|Special Program for New Branch||$xx,xxx||$xx,xxx|
|Direct Mail Campaign||$xx,xxx||$xx,xxx|
|Other Promotional Expenses||$xx,xxx||$xx,xxx|
Provide an overview of management’s timeframe to implement key provisions of the marketing plan (not just a calendar of events). The timetable may be broken into quarterly segments covering at least the first two years after conversion or expansion.
Describe marketing efforts, implementation of any new products or services, and any new service delivery mechanisms such as branch offices.
Example: ABC Federal Credit Union will implement the following strategy for the first two years after approval of the community charter:
|1st quarter||Radio and television campaign covering the entire community promoting the credit union as open to all residents. Purchase billboard advertising along major roadways. Begin social media advertising. Conduct financial literacy seminars each month.|
|2nd quarter||Direct mail promoting loans and share draft accounts to one half of the community. Continue television and radio advertising. Advertise in Sunday newspaper. Conduct budget workshops each month.|
|3rd quarter||Open new branch. Direct mail to second half of community. Continue television, radio, and newspaper advertising. Promote financial counseling services and financial literacy seminars.|
|4th quarter||Continue television, radio, social media, and newspaper advertising. Staff to volunteer in community parade to promote credit union.|
|5th quarter||Promote auto loans and share draft accounts on television, radio, social media, and newspapers.|
|6th quarter||Continue television, radio, and newspaper advertising. Promote financial counseling services and financial literacy seminars.|
|7th quarter||Continue social media outreach. Direct mail to one-half of community. Promote electronic service delivery and youth accounts.|
|8th quarter||Direct mail to second half of community. Continue television, radio, and newspaper advertising.|