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April 4, 2014 – NAFCU Regulatory Affairs Counsel PJ Hoffman details the association's talking points on NCUA's proposed risk-based capital rule today in a Compliance Blog post, reminding members that comments are due to the agency by May 28.

NCUA issued its own reminder Thursday, also touting the agency's online risk-based capital calculator. NAFCU has also created a calculator, but that calculator allows credit unions to substitute their own weights and see how the proposed rule would affect their net worth ratios now and after five years, based on their assumptions about asset growth and annual return on assets, or ROA.

"This is a very important issue for the credit union industry, and it is important that your credit union weighs in on the rule's possible effects with NCUA," Hoffman writes. "NAFCU's talking points for comment letters are based on NAFCU's analysis of the proposed rule that your credit union can use when formulating your comment letters to NCUA. The talking points should be colored with the views and opinions of your credit union."

Hoffman asks members to: send NAFCU comments on the rule; send NCUA comment letters; watch NAFCU's April 10 webcast on how the proposal will affect credit unions; and consider sending a staff member to a listening session with NCUA Chairman Matz this summer – free events limited to 150 attendees each, scheduled to occur in Los Angeles, Chicago, and Alexandria, Va.

In NAFCU's talking points, the association identified several specific areas of concern in the proposed rule, including: the risk-weights for non-delinquent first mortgage real estate loans, credit union service organizations, investments, member business loans, the individual minimum capital requirement and the rule's implementation period.