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July 15, 2014 – NAFCU witness David Clendaniel, president and CEO of Dover Federal Credit Union in Dover, Del., will let lawmakers know "enough is enough" when he testifies today on the impact of overregulation on credit unions before a House subcommittee.

During a 2 p.m. hearing, Clendaniel will discuss regulatory relief and how overregulation has hurt his credit union at a hearing of the House Financial Services Subcommittee on Financial Institutions and Consumer Credit, chaired by Rep. Shelley Moore Capito, R-W.Va. He will talk about various regulatory relief proposals, the impact of new rules on his credit union's operation and members since the enactment of the Dodd-Frank Act, and rules yet to come.

In his written testimony, Clendaniel particularly emphasizes the concerns surrounding NCUA's proposed risk-based capital rule.

"Despite NCUA's refusal to extend the official comment period, the recent listening sessions on the proposal in Los Angeles, California, and Chicago, Illinois, reinforce the need for significant changes to the proposal and additional time for credit unions to digest the proposal and come into compliance," Clendaniel says in today's prepared remarks.

"If NCUA implements changes to the proposed rule in accordance with even some of the 2,000 comments received, the changes will be substantive and more than mere adjustments or clarifications to the initial proposal," Clendaniel pointed out, explaining that that would require a second comment period under the Administrative Procedure Act.

Today's hearing will address several bills offered in the House with the goal of providing regulatory relief to community financial institutions, including credit unions.

Clendaniel will testify on several of these, including H.R. 4042, the Community Bank Mortgage Servicing Asset Capital Requirements Study Act. NAFCU is urging that NCUA be required to conduct an impact study before implementing any final rule on risk-based capital.

Carrie Hunt, NAFCU's senior vice president of government affairs and general counsel, said NAFCU appreciates that NCUA has indicated it plans changes to the risk-based capital rule. "We are working with the agency and will continue to do so," she said, "but we plan to use all the tools at our disposal to ensure that any final rule is fair to all credit unions."

Today's hearing will also feature testimony from representatives of the American Bankers Association, the Independent Community Bankers Association, the National Consumer Law Center, and Americans for Financial Reform.