Comments Due to NAFCU: NCUA - Subordinated Debt
NAFCU would like to highlight the following:
- The proposal amends the definition of “Grandfathered Secondary Capital” in the NCUA’s 2020 Subordinated Debt Rule (Subordinated Debt Rule) to include secondary capital issued to the Government through an application approved before January 1, 2022, irrespective of the date of issuance.
- Secondary capital issued to the Government after January 1, 2022, but approved before 2022, would be regarded as Grandfathered Secondary Capital for the later of 20 years from the date of issuance or January 1, 2042.
- The proposal also clarifies that the maximum maturity for Grandfathered Secondary Capital applies to Government investments in secondary capital.
Comments due to NAFCU: October 15, 2021
Comments due to NCUA: October 28, 2021
NAFCU will send comments on behalf of its members to the NCUA by their deadline (October 28, 2021).