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NAFCU issued a Regulatory Alert yesterday on NCUA's second risk-based capital proposal and is asking members to provide their input to the association by April 3. The proposal would set RBC requirements for "complex" federally insured credit unions.

The Alert notes that NAFCU is "very concerned about the proposal's impact on credit union capital buffers. Despite NCUA's claim that only a limited number of credit unions will be impacted, this proposal would force credit unions to hold hundreds of millions of dollars in additional reserves to achieve the same capital cushion levels that they currently maintain."

The Alert continues, "NAFCU strongly believes this rulemaking is unnecessary and will only impose more regulatory burden on an already extremely well-capitalized industry."

Comments will be due to NCUA 90 days after the proposal's publication in the Federal Register.

NAFCU is reviewing all aspects of the proposed rule. On Tuesday, NAFCU released its new member-only risk-based capital calculator with a feature that NCUA doesn't include on its own version: five-year forecasting based on estimated return on assets and asset growth rates.

The updated calculator takes into account numerous changes NCUA made in its new proposal, including updated asset risk weights that credit unions will use to determine their RBC ratios. NAFCU's calculator also allows credit unions to find their current ratio as well as adjust risk weights to see their impact on their RBC ratios.