American Bankers Association v. National Credit Union Administration

The National Credit Union Administration (defendant) had authority to promulgate rules and regulations for the administration of the Federal Credit Union Act. In 1998, Congress enacted the Credit Union Membership Access Act (the access act), which amended the Federal Credit Union Act. The National Credit Union Administration issued a final rule regarding member standards for federal credit unions, implementing the 1998 amendments from the access act. The final rule touched on several issues, including whether family members count toward a certain member limit imposed by statute and the continued application of a grandfather clause provided for by statute. The National Credit Union Administration found that the credit-union statutes were ambiguous in some respects and provided its own interpretations of several statutory provisions. The American Bankers Association (the association) (plaintiff) sued the National Credit Union Administration in federal district court pursuant to the Administrative Procedure Act, raising several issues with the rule. The association argued that several provisions of the rule violated the access act because the National Credit Union Administration improperly interpreted portions of the access act that were unambiguous. In other words, the association’s argument was that the National Credit Union Administration’s interpretations of the access act were not entitled to deference because the access act was not ambiguous, so the plain meaning of the statutory language, rather than the National Credit Union Administration’s interpretations, controlled. The district court dismissed the association’s claim for failure to state a claim, finding that the National Credit Union Administration was entitled to deference, and that its interpretations of the access act were reasonable. The association appealed, focusing its appeal on step one of the Chevron test.