While CUNA supports NCUA’s proposed delay of NCUA’s risk-based capital rule, it maintains that the rule continues to be “functionally unnecessary. CUNA submitted its comment letter Thursday on NCUA’s proposal, which would delay the rule’s implementation to Jan. 1, 2020, and raise the asset threshold for defining a complex credit union.

“The data continues to clearly show that the rule is a solution looking for a problem…RBC places significant unnecessary burdens on credit unions and needlessly coerces credit union asset allocations—all at a significant cost to credit union members,” CUNA’s letter reads. “Should the agency choose to forego common-sense restraint and pursue the RBC rule as re-proposed, CUNA urges meaningful change.”

Specifically, the proposal would raise the threshold for risk-based capital compliance to $500 million in assets, up from $100 billion. CUNA believes this should be set at $10 billion in assets, aligning with eligibility for supervision under NCUA’s Office of National Examinations and Supervision.

“Maintenance of disparate asset thresholds among rules from myriad departments and divisions across federal and state regulatory bodies contributes to duplicative and inconsistent oversight,” the letter reads.