Advance question, no surprises....
Ms. Kristina W. Ray
N.C. Administrator of Credit Unions
Raleigh, North Carolina
October 2, 2025
Re: N.C. Credit Union Commission Meeting
Dear Ms. Ray,
Thank you for your prompt response, concerning the time, location, and agenda of the October 8, 2025 Commission meeting.[link]
Since
you are accepting not only comments but also questions under agenda
item XI, I thought it might be helpful to submit my question in advance
for your consideration. Hopefully that would enable you to respond at
the meeting. As you'll note the question is not directed at any specific
credit union, nor any proposed or existing bylaw amendments.
As the Administrator of North Carolina Credit Unions, N.C. state statutes give you broad authority [NCGS § 54‑109.12.]
to regulate the actions of credit unions "... as to their conduct,
organization, management, business practices and their financial and
fiscal matters." Included in that authority is the requirement that you
approve the initial bylaws of a credit union and all subsequent
amendments.
My question is: Would you as the Administrator consider - subject of
course to actual submission and specific wording - North Carolina
credit union bylaw amendments which specified the following concepts:
* Term limits for directors.
* Age limits for directors.
* That all eligible and qualified director candidates be placed on the annual ballot.
* That at least two qualified candidates be on the ballot for each director vacancy.
* Signature petitions not be required for eligible and qualified director candidates.
* That bylaw amendments be fully disclosed and approved by members prior to submission to the Administrator.
*
That proposals to buy commercial banking institutions be prohibited or
be fully disclosed and require a majority vote of the members.
* That proposals to change charters be fully disclosed in advance and approved by a majority of members.
*
Provide for members to vote for a distribution of equity in the event
of a change in charter, while maintaining the safety and soundness of
the continuing institution.
* That a majority vote of all eligible members be required on significant bylaw amendments.
All
these possibilities appear to be currently permissible under both state
and federal credit union laws, with many of the provisions already in
place within the existing bylaws of North Carolina credit unions.
As
the government leader empowered to interpret state credit union laws,
your confirmation as Administrator of permissibility would be helpful
and important.
Look forward to your response. If it would be helpful to you and
the Commission, I would be happy to also submit my comments in advance
Thank you.
Sincerely,
Jim Blaine
North Carolina Credit Union member
