## Facts

- The Federal Credit Union Act (FCUA) limits federal credit union membership to “groups having a common bond of occupation or association,” or to groups within a defined geographic community.
- The National Credit Union Administration (NCUA) adopted a policy (beginning in 1982) allowing a single occupational federal credit union to include multiple, unrelated employer groups, each sharing its own occupational bond.
- NCUA approved charter amendments for AT&T Family Federal Credit Union permitting it to add unrelated employer groups, resulting in a large, geographically dispersed membership in which a minority were AT&T employees or affiliates.
- Several commercial banks and the American Bankers Association sued under the Administrative Procedure Act (APA), asserting that NCUA’s policy violated FCUA § 109 because it required one common occupational bond uniting all members of an occupational credit union.

## Issues

1. Whether the banks and their trade association had prudential standing under APA § 10(a) because their competitive interests were arguably within the “zone of interests” protected or regulated by FCUA § 109.
2. Whether FCUA § 109 permits NCUA to approve federal credit unions composed of multiple unrelated employer groups, or instead requires a single occupational common bond for the entire credit union membership.

## Decision

- The Supreme Court affirmed the judgment of the D.C. Circuit in a 5–4 decision authored by Justice Thomas.
- The Court held that the banks and the trade association had prudential standing under the APA because their competitive interests were arguably within the zone of interests implicated by § 109’s membership limitation.
- The Court held that NCUA’s multiple-group interpretation of § 109 was impermissible because the statute unambiguously requires that the same occupational common bond unite the members of an occupational federal credit union.
- Because the statute was unambiguous, the Court rejected deference to NCUA’s contrary interpretation.

## Legal Principles

- Under APA § 10(a), a plaintiff has prudential standing if the interest asserted is arguably within the zone of interests to be protected or regulated by the statute at issue.
- Competitors may fall within the zone of interests where an agency action relaxes statutory limits governing a competing, regulated financial institution’s authorized scope or membership.
- Under Chevron step one, if Congress has spoken clearly to the precise question, an agency interpretation that conflicts with the statute’s unambiguous meaning is invalid.
- FCUA § 109’s occupational membership clause requires one common occupational bond uniting all members of an occupational federal credit union; it does not allow aggregation of unrelated employer groups into a single credit union solely because each subgroup has its own internal bond.

## Conclusion

The Court held that competing banks could seek APA review of NCUA’s field-of-membership policy and that FCUA § 109 unambiguously limits occupational federal credit unions to a single shared common bond, invalidating NCUA’s multiple-group occupational credit union approach.


Nat’l Credit Union Admin. v. First Nat’l Bank & Tr. Co., 522 U.S. 479 (1998)