WASHINGTON (1/20/15)--With the release of the National Credit Union Administration's revised risk-based capital proposal (RBC2), credit unions should be prepared to analyze the proposal and engage in the regulatory process, says Credit Union National Association President/CEO Jim Nussle. The CUNA leader sent a letter to members of the U.S. Senate and House Friday with information about the proposal, as well CUNA's stance on the revised plan.
"We need to continue our engagement and continue taking a very careful look at what's in the rule. We want to know how the different parts of the proposal will impact the entire credit union community," Nussle said. "The devil is very clearly in the details, and those details are things credit union stakeholders will understand much more acutely as those involved in the day-to-day operations of your institutions. So we need to hear how it impacts you."
NCUA Chair Debbie Matz, Vice Chair Rick Metsger and board member J. Mark McWatters all cited the 2,056 comment letters received on the initial proposal as a major impetus behind many of the changes. In addition, a major part of the agency's 500-page RBC2 plan takes up many CUNA concerns and comments.
See the below video to hear Nussle's thoughts on how credit unions can help shape RBC2 going forward by engaging and analyzing the proposal.
Also, CUNA will be posting an RBC estimator tool online this week, which will help individual credit unions get a glimpse at how the proposal would directly affect them. (See related story: Still time to sign up for CUNA RBC2 webinar with NCUA's Fazio.)
"With reductions in many of the risk weights, and reducing to 10% the well-capitalized requirement, much of the damage of the original proposal appears to have been alleviated, but we're double checking all the calculations," said Bill Hampel, CUNA chief policy officer. "In addition, although interest-rate risk and individual minimum capital requirements are not in RBC2, we are concerned about how the agency might replace them in other new rules."
CUNA's regulatory advocacy staff will also release its analysis this week of the RBC2 proposal and other items covered at the NCUA's Jan. 15 board meeting this week.