Compliance Blog

Apr 04, 2014
Categories: Operations

Talking Points for Risk-Based Capital Proposed Rule Comment Letter; NAFCU Webcast on What Policies Must be Board-Approved

Written by PJ Hoffman, Regulatory Affairs Counsel

Welcome back to the latest installment of our recurring series of posts where NAFCU’s Compliance Blog discusses NCUA’s proposed rule regarding risk-based capital and provides you with resources to help your credit union understand the impact of the rule. Today’s topic is our newest resource for your credit union: NAFCU’s talking points for your comment letters to NCUA.

Some quick background, on January 23, 2014, the NCUA Board issued a proposed rule regarding risk-based capital for credit unions. We at NAFCU are working around the clock for you and have created some helpful resources for our members to use including NAFCU’s Regulatory Alert 14-EA-03, NAFCU Compliance Blog Posts here, here, here, here, NAFCU’s risk-based net-worth calculator, and the Capital Reform Issue Page.

This is a very important issue for the credit union industry and it is important that your credit union weighs in on the rule’s possible effects with the NCUA. Getting your voice heard is simple and here are four things your credit union should do right now. First, send us your comments here regarding the rule so that we can incorporate them into our advocacy and comment letter.  We have extended the deadline from April 1, 2014 to April 15, 2014 so get those comments in.

Secondly, your credit union should write a comment letter to NCUA explaining how the rule will affect your credit union and the industry as a whole. We have put together a very helpful tool for our members to help with putting your comment letters together. NAFCU’s talking points for comment letters are based on NAFCU’s analysis of the proposed rule that your credit union can use when formulating your comment letters to NCUA. The talking points should be colored with the views and opinions of your credit union, but there are a number of helpful arguments available that are broken down by topic. Remember comment letters are due to NCUA by May 28, 2014.

Third, check out our upcoming webcast on April 10, 2014 entitled “Risk-Based Capital Rule: How NCUA’s Proposal Will Impact You.”  It will break down the issues with the rule and its impact on your credit union with special guest speaker Denise Boutross McGlone from Affinity FCU. Be sure to tune in for an overview of the proposed rule as well as the impact it could have on your credit union’s operations now and in the future.

Finally, consider sending someone from your credit union to one of NCUA Chairman Matz’s listening sessions. NCUA has opened registration for its three listening sessions in Los Angeles, Chicago and Alexandria, Va., this summer, before a final capital rule is issued. These are free events but participation in each is limited to the first 150 people registering. Both NCUA Chairman Debbie Matz and Board Member Rick Metsger will attend the sessions and this is a great opportunity to follow up on your comment letters and talk directly with two members of the NCUA Board.

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Webcast: NCUA Board of Director Policies: Which Ones Truly Require Action?

Lighten your compliance burden! Andy Keeney will discuss how you can significantly reduce the attention you give to 35 of NCUA’s “required” Board of Director policies. You’ll also learn the remaining 15 policies your Board must absolutely act upon.