For now, the GAO recommended that the NCUA track the income levels of credit union members, and perhaps expand and refine its pilot program to better track who its members are and which services they're using.

NCUA chairwoman JoAnn Johnson released a statement the day the GAO report came out, looking ahead to "additional discussions" to come.

"GAO's acknowledgement of the restrictions federal credit unions face regarding who they are legally able to serve is a critical aspect that merits additional discussion by Congress," Johnson wrote. "It is also encouraging that the GAO report notes that federal credit unions are taking advantage of the available avenues, such as low-income designation and addition of underserved areas, to serve members in all income strata. We welcome this discussion, as well as the process by which Congress has learned more about federal credit union member service."

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