480
Syllabus
See, e. g., Association of Data Processing Service Organizations, Inc. v. Camp, 397 U. S. 150, 152-153. P. 488. (b) Although this Court's prior cases have not stated a clear rule for determining when a plaintiff's interest is "arguably within the zone of interests" to be protected by a statute, four of them have held that competitors of financial institutions have prudential standing to challenge agency action relaxing statutory restrictions on those institutions' activities. Data Processing, supra, at 157; Arnold Tours, Inc. v. Camp, 400 U. S. 45, 46 (per curiam); Investment Company Institute v. Camp, 401 U. S. 617, 621 (ICI); Clarke v. Securities Industry Assn., 479 U. S. 388, 403. Pp. 488-492.
(c) In applying the "zone of interests" test, the Court does not ask whether Congress specifically intended the statute at issue to benefit the plaintiff, see, e. g., Clarke, supra, at 399-400. Instead, it discerns the interests "arguably . . . to be protected" by the statutory provision and inquires whether the plaintiff's interests affected by the agency action in question are among them, see, e. g., Data Processing, supra, at 153. By its express terms, § 109 limits membership in every federal credit union to members of definable "groups." Because federal credit unions may, as a general matter, offer banking services only to members, see, e. g., 12 U. S. C. §§ 1757(5)-(6), § 109 also restricts the markets that every federal credit union can serve. Although these markets need not be small, they unquestionably are limited. The link between § 109's regulation of membership and its limitation on the markets that can be served is unmistakable. Thus, even if it cannot be said that Congress had the specific purpose of benefiting commercial banks, one of the interests "arguably . . . to be protected" by § 109 is an interest in limiting the markets that federal credit unions can serve. This interest is precisely the interest of respondents affected by the NCUA's interpretation of § 109. As competitors of federal credit unions, respondents certainly have an interest in limiting the markets that federal credit unions can serve, and the NCUA's interpretation has affected that interest by allowing federal credit unions to increase their customer base. Section 109 cannot be distinguished in this regard from the statutory provisions at issue in Clarke, ICI, Arnold Tours, and Data Processing. Pp. 492-495.
(d) Respondents' interest is therefore arguably within the zone of interests to be protected by § 109. Petitioners principally argue that respondents lack standing because there is no evidence that the Congress that enacted § 109 was concerned with commercial banks' competitive interests. This argument is misplaced. To accept that argument, the Court would have to reformulate the "zone of interests" test to require that Congress have specifically intended to benefit a particular
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