WASHINGTON (3/26/15)--With 22 working days left until the comment deadline for the risk-based capital proposal--often referred to as RBC2, CUNA is providing new resources in its effort to encourage credit unions to weigh in. Again.
The deadline is April 27.
The National Credit Union Administration abandoned its original RBC plan, issued in January 2014, after it received 2,056 comments from credit unions, lawmakers and others that listed concerns regarding how the plan would impact credit unions and consumers.
The agency issued its second RBC proposal this January, and CUNA has said it is a substantially improved regime--but still a solution in search of a problem.
"With reductions in many of the risk weights found in the original plan, and a reduction to 10% for the well-capitalized requirement, the second proposal is an improvement," says Bill Hampel, CUNA chief policy officer.
However, he emphasizes there are still significant problems with the proposal, particularly as it relates to an additional "capital adequacy" requirement, and the future treatment of interest-rate risk so it is imperative that credit unions stay engaged in this rulemaking process to have as much impact on proposal improvements as possible.
As part of its new resources, CUNA has developed a "comment letter guide" with information regarding the need for and value of commenting on the plan and how to comment.
"There remain a number of areas that should still be improved, and they are described in the guide," Hampel says.
"We are asking credit unions to individually tell their stories to NCUA, so the agency understands that their rule will have real impact on real credit unions and their very real members," CUNA's chief policy officer adds.