Ready for Six? Updating FCU Bylaws for Board Meeting Flexibility
Eligible federal credit unions may now hold as few as six regular board meetings each year, rather than meeting monthly, provided at least one regular meeting occurs during each fiscal quarter.
The change was enacted through the Credit Union Board Modernization provisions in Title IX of the 21st Century ROAD to Housing Act, P.L. 119-101, which became law on July 11, 2026. The law amended Section 113 of the Federal Credit Union Act and replaced the former blanket monthly board-meeting requirement with a risk-based structure.
Under the new framework:
De novo FCUs in their first five years of operation must continue meeting at least monthly.
FCUs with a composite CAMELS rating of 1 or 2 and a management-component rating of 1 or 2 may meet at least six times annually, including at least once each fiscal quarter.
FCUs with a composite CAMELS rating or management-component rating of 3, 4, or 5 must continue meeting at least monthly.
NCUA has advised that these statutory amendments are self-executing. Although NCUA plans to revise its regulations and standard FCU Bylaws, an eligible FCU may amend its bylaws now and begin using the new flexibility immediately. NCUA further states that the FCU does not need to submit the bylaw amendment to NCUA for approval.
A note for state-chartered credit unions
The new meeting-frequency provision directly applies to federal credit unions. State-chartered credit unions should not assume the six-meeting option automatically applies to them. Before changing the board-meeting calendar or bylaws, review applicable state law, state regulator guidance, and the credit union’s current bylaws.
Practical steps for FCUs
Eligible FCUs considering the reduced meeting schedule should:
Confirm eligibility. Verify that the FCU has been operating for more than five years and that its most recent composite CAMELS rating and management-component rating are each 1 or 2. An FCU with a composite CAMELS rating or management-component rating of 3, 4, or 5 must continue to meet at least monthly.
Review governing documents. Identify provisions that require or assume monthly regular board meetings. For most FCUs, the relevant language will appear in the regular-and-special-meetings section within the board article. Also review board policies, standing resolutions, and the annual board calendar for a separate monthly requirement.
Adopt a narrow bylaw amendment. The amendment should address the monthly regular-meeting requirement and align it with the new statutory minimum of at least six regular meetings annually, including at least one meeting each fiscal quarter. Existing provisions governing meeting format, notice, special meetings, quorum, minutes, director attendance, and action without a meeting should remain unchanged unless the FCU intends a separate, independently supported revision.
Follow the FCU’s adoption process. Obtain the required board vote under the FCU’s existing bylaws, document the action in the board minutes, update the official and member-facing copies of the bylaws, and retain the NCUA guidance and eligibility support in the governance file.
Update meeting practices. Establish an annual board calendar with at least six regular meetings and at least one meeting per fiscal quarter. The new law establishes a minimum, not a maximum; boards may continue to meet monthly or more often when that best supports oversight, strategy, risk management, and operations.
Need help with the amendment?
Because NCUA has not yet published revised standard bylaw language, each FCU should review its current bylaws carefully and tailor any amendment to its existing language. A narrowly drafted amendment may be appropriate, but the wording should be evaluated in the context of the FCU’s complete bylaws and governance practices.
If this is a change your credit union would like to make and you need help reviewing your current bylaws or drafting a limited amendment, reach out to Crimson Oak Strategies. We would be happy to help evaluate your existing bylaw language, identify related governance considerations, and prepare an amendment that reflects the new board-meeting flexibility.
What happens when NCUA updates the standard bylaws?
NCUA has not yet published revised model bylaw language or stated that FCUs using the self-executing process must later adopt NCUA’s revised wording. Based on NCUA’s instruction that an eligible FCU may amend its bylaws now and use the new meeting flexibility immediately without advance approval, the FCU’s properly adopted amendment should remain effective unless NCUA’s future rule expressly requires a conforming amendment.
FCUs should monitor NCUA’s upcoming rulemaking and compare any future model language to their adopted provision. In the absence of a future mandatory conforming requirement, an FCU should be able to retain its properly adopted, narrowly tailored meeting-frequency language.
Bottom line
Eligible FCUs do not have to wait for NCUA to update its model bylaws before using the six-meeting option. Confirm that the FCU has operated for more than five years and has composite and management ratings of 1 or 2, adopt a focused bylaw amendment, document the board’s action, and update the annual meeting calendar. The flexibility is optional—each FCU should choose the meeting cadence that best supports effective board oversight.
