Resources to help you navigate the changing regulatory landscape

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Is a Merger the Right Fit for Your Credit Union?

Year after year, the number of credit unions continues to decline. According to NCUA Q3 2025 data, there were 4,331 credit unions nationwide, down from 4,370 in Q2. Mergers remain a primary driver of consolidation, occurring for a variety of reasons including succession challenges, membership expansion, competitive pressures, and increasing technology and compliance demands.

Effective January 1, 2026, the NCUA’s new succession planning rule requires all federally insured credit unions (FISCUs) to maintain a board-approved succession plan for covered positions. These positions include the CEO, board members, senior executives, management, and other roles deemed critical to operations. The intent of the rule is to reduce unplanned mergers driven by leadership gaps, particularly as long-tenured executives retire. Having a defined plan for filling vacancies and preventing attrition in the first place is a good defense against unwanted and unplanned mergers. However, not all mergers are reactive. Many are strategic.

Although the number of credit unions continues to decline, total industry assets are growing. As of Q3 2025, total assets increased by $86 billion. Credit unions with $1 billion or more in assets reported the strongest gains in shares, loans, membership, and net worth. The average credit union now holds approximately $522 million in assets, and projections from the CEO Advisory Group suggest the average could reach $3.4 billion by 2040. Strategic mergers will likely play a significant role in this continued asset growth.

Determining Whether a Merger Makes Strategic Sense

For credit unions considering a voluntary, growth-oriented merger, the first and most important question is: Does this add value for our members?

A merger should enhance the member experience. Consider whether it would:

  • Expand products and services
  • Improve technology and digital capabilities
  • Increase capital and lending capacity
  • Strengthen long-term leadership and succession planning
  • Expand geographic reach and field of membership

If the answer is yes, the next step is defining your merger strategy.

Defining Your Objectives and Non-Negotiables

Before engaging potential partners, leadership and the board should clearly articulate:

  • What are our strategic goals?
  • What problems are we trying to solve?
  • What are our non-negotiables?
  • What cultural or operational attributes are essential in a partner?

Clarity at this stage prevents misalignment later in the process.

Identifying the Right Partner

Potential partners are not always publicly seeking mergers. Identifying the right fit may require direct outreach or assistance from firms experienced in credit union mergers and acquisitions.

Initial discussions typically involve the CEOs and boards assessing whether a merger would benefit both memberships. Engaging experienced third-party advisors can help ensure critical questions are addressed objectively. A non-disclosure agreement (NDA) should be executed before sharing confidential information.

Key early discussion points often include:

  • Strategic benefits to each membership
  • Alignment of mission, vision, and core values
  • Cultural compatibility
  • Compliance philosophy and risk appetite
  • Structure of the transaction (merger into vs. merger of equals)
  • Leadership structure, including CEO selection
  • Board composition
  • Branding and name considerations
  • Charter implications
  • Headquarters and branch footprint

If alignment exists, the parties can move into formal negotiations and due diligence.

Due Diligence and Financial Analysis

Once both boards agree to proceed, comprehensive due diligence begins. Collaboration with legal counsel and CPA firms is essential.

Areas of review typically include:

  • Financial statements and fair value assessments
  • Loan portfolio quality and delinquencies
  • Capital adequacy
  • Operational processes
  • Compliance framework
  • Vendor contracts, including any termination penalties
  • Financial projections post-merger

Thorough due diligence protects both institutions and ensures there are no unexpected risks.

Regulatory Approval and Membership Vote

After completing due diligence and finalizing terms, the merger package must be submitted to the NCUA. The package includes:

  • Rationale for the merger
  • Resolution of the Boards
  • Evidence of state supervisory authority approval (if necessary)
  • Proposed effective date
  • Consolidated financial information
  • Share insurance documentation
  • Signed certification by the CEO and Chairmen of the Boards

The merging credit union’s membership must approve the merger by vote. Members must receive notice at least 45 days, but no more than 90 days, before the vote. Proactive communication prior to the notice is critical, however. Clearly explaining the “why” behind the merger helps members feel informed and increases the likelihood of participation.

Following regulatory and membership approval, the merger may be completed. The board of the continuing credit union must certify completion to the appropriate Regional Director within 30 days of the effective date.

Integration: The Work Continues

Regulatory approval is not the finish line. Integration requires deliberate planning and execution.

Leadership should:

  • Provide detailed transition timelines for employees and members
  • Clearly define roles and responsibilities
  • Monitor systems, transactions, and operational performance
  • Maintain open communication throughout the transition

While no merger is seamless, preparation significantly improves outcomes.

Final Thoughts

When thoughtfully planned and strategically aligned, mergers can position a credit union for long-term growth, stronger leadership, and enhanced member value.

The key is clarity: understand your “why,” define your must-haves and non-negotiables, conduct thorough due diligence, and communicate transparently and honestly. With the right preparation, a merger can be not just a solution—but an opportunity.

Have questions or want to know more? Email us at compliancesupport@viclarityus.com.

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For More Information

For more information, email Heather Line.

Access the ‘Compliance Hotline’

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Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!

Additionally, other League-member compliance resources include:

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  • InfoSight
  • CU Store
  • Record Retention Guide
  • GRC Technology Solutions

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