As you are aware, through a years-long series of discussions with the Department of Defense (DoD), and through the enactment of an amendment to the Federal Credit Union Act in 2006, the DoD has the discretionary authority to afford space on military bases at a nominal rate to credit unions provided that they meet certain statutory and regulatory requirements regarding the provision of financial services in the on-base facility. Now, due to bank lobbying efforts, the Senate’s version of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 contains language which would require the DoD to treat all banks the same as credit unions on military installations when it comes to leases. A similar provision was rejected last year during the Conference Committee between the House and Senate for the FY 2020 NDAA.
NAFCU recognizes the important role both credit unions and banks can play for our men and women in the military in the provision of traditional financial services and in protecting our troops from predatory lenders. However, we remain concerned that efforts to provide "free rent" for banks on military installations are missing the mark, and would disadvantage credit unions. The proposed language could essentially require that the DoD treat Wells Fargo the same as a military installation’s local not-for-profit defense credit union when it comes to rent on military bases.
NAFCU encourages you to contact your Senators and urge them to reject the inclusion of any provision in the Senate version of the NDAA that would extend nominal leases to banks and call on them to gauge the full impact of any specific statutory language the banks may seek prior to supporting any such provision.