1,850 RBC letters and counting
NCUA's proposed risk-based requirements would affect CUs over $50 million in assets; most credit unions closed or merged with assistance from 2003-2012 were smaller and accounted for nearly half the losses to the share insurance fund.
May 30, 2014 – NCUA staff yesterday morning said the agency had counted 1,850 comment letters so far, and was still processing letters, on its risk-based capital proposal – making this round already the largest number received on a proposed rule since 1995.
In 1995, NCUA received 1,300 comment letters in its first round of comments on a proposed corporate rule, which was out for a 120-day comment period. NCUA later issued a new proposal.
In its comment letter submitted Tuesday, NAFCU urged NCUA to withdraw its risk-based capital proposal or make significant changes, all outlined in the letter, and go out for a second round of comments on a new one. It has urged at least a three-year implementation period for any final rule.
NCUA Board Chairman Debbie Matz has been talking recently in the trade press and in the agency’s own newsletter about possible changes to the current proposal – in how risk weights are “calibrated,” through added clarity on the individual minimum capital requirements and more time for implementation than the 18 months proposed.
Matz is hosting three listening sessions in June and July where credit unions will be able to raise any issues they choose to raise. She has said the sessions will precede the issuance of any final risk-based capital rule.
Two weeks ago, 324 House members signed and delivered to Matz a letter urging consideration of the proposed rule’s potential costs for credit unions, more time for credit unions to comment for the record and “justification and clarity” on why NCUA’s proposed risk weights are different than standards used for other community financial institutions.
NAFCU comment letter
NCUA listening sessions
House members' letter to Matz
"Final count: 324 in House sign letter sent to Matz on RBC," 5/16/14