486
Opinion of the Court
The Court of Appeals for the District of Columbia Circuit reversed. First Nat. Bank & Trust Co. v. National Credit Union Admin., 988 F. 2d 1272, cert. denied, 510 U. S. 907 (1993). The Court of Appeals agreed that "Congress did not, in 1934, intend to shield banks from competition from credit unions," 988 F. 2d, at 1275, and hence respondents could not be said to be "intended beneficiaries" of § 109. Relying on two of our prudential standing cases involving the financial services industry, Investment Company Institute v. Camp, 401 U. S. 617 (1971), and Clarke v. Securities Industry Assn., 479 U. S. 388 (1987), the Court of Appeals nonetheless concluded that respondents' interests were sufficiently congruent with the interests of § 109's intended beneficiaries that respondents were "suitable challengers" to the NCUA's chartering decision; therefore, their suit could proceed. See 988 F. 2d, at 1276-1278.1
On remand, the District Court applied the two-step analysis that we announced in Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837 (1984), and held that the NCUA had permissibly interpreted § 109. 863 F. Supp. 9 (DC 1994). It first asked whether, in enacting § 109, Congress had spoken directly to the precise question at issue—whether the same common bond of occupation must unite members of a federal credit union composed of multiple employer groups. See id., at 12. It determined that because § 109 could plausibly be understood to permit an occupationally defined federal credit union to consist of several employer "groups," each having its own distinct common bond of occupation, Congress had not unambiguously addressed this question. See ibid. The District Court then
1 The Court of Appeals' holding that respondents had prudential standing conflicted with a decision of the United States Court of Appeals for the Fourth Circuit reached prior to this Court's decision in Clarke v. Securities Industry Assn., 479 U. S. 388 (1987). See Branch Bank & Trust Co. v. National Credit Union Administration Bd., 786 F. 2d 621 (1986), cert. denied, 479 U. S. 1063 (1987).
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