MEMORANDUM OPINION
KOLLAR-KOTELLY, District Judge.
For years, the National Credit Union Administration (NCUA) interpreted Section 109 of the Federal Credit Union Act (FCUA), 12 U.S.C. § 1759, to permit various employment groups, each one united by its own peculiar occupational bond but otherwise unrelated to another group, to coalesce and form a "multiple common-bond" credit union. See Interpretative Ruling and Policy Statement (IRPS) 82-1, 47...
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