Comments on proposals from several federal agencies that will have an effect on credit unions are due in the month of July, including on risk-based capital, same-day automated clearing house (ACH) changes and more.

The NCUA proposed a delay of its risk-based capital rule at its June meeting. Currently scheduled to go into effect Jan. 1, 2020, the proposed delay would make the rule effective Jan. 1, 2022.

While NCUA made modifications to the rule in October 2018 (which included delaying implementation from 2019 to 2020), CUNA continues to believe the rule is unnecessary.

Comments on the proposed delay are due July 26.

Other comment deadlines this month include:

• July 15: Federal Reserve request for comment on potential modifications Federal Reserve Banks' National Settlement Service and Fedwire Funds Service to support enhancements to the same-day ACH service, which would will add a third daily processing window; and
• July 29: NCUA’s proposal to allow federal credit unions to receive public unit and nonmember shares up to 50% of a credit union’s paid-in and unimpaired capital and surplus, less any public unit and nonmember shares.

Comments on an advance notice of proposed rulemaking from the Consumer Financial Protection Bureau on Home Mortgage Disclosure Act data points were originally due July 8, but the CFPB has extended the deadline to Oct. 15.