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April 17, 2014 – NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt reminded association members in an email Wednesday that they have just six weeks left to get their comment letters to NCUA on the proposed risk-based capital rule.

Hunt called the capital proposal "the most important rule" NCUA has put forward in recent memory and said it is critical that credit unions provide the agency their input.

NAFCU identified several specific areas where member comments can make a big difference, including:

• the proposal's risk weights for non-delinquent first mortgage real estate loans, investments and member business loans;
• the individual minimum capital requirement; and
• the rule's implementation period.

Hunt also mentioned NAFCU's adjustable risk-based net-worth calculator, which can help credit unions see how the proposed rule would affect them.

The talking points are available on NAFCU's capital reform webpage as a member-only resource.