National Credit Union Administration: Delay of Effective Date of the Risk-Based Capital Rules
NAFCU would like to highlight the following:
- The NCUA intends to utilize the two-year delay to “holistically and comprehensively evaluate capital standards” for federally insured credit unions. In practical terms, this will entail consideration of whether asset securitization and subordinated debt should be addressed before the risk-based capital rule takes effect, and whether a community bank leverage ratio analog should be adopted as a mechanism for additional relief. Each of these items would be presented through separate and distinct rulemaking efforts.
- The preamble clarifies that under the proposal, the NCUA's existing prompt corrective action (PCA) regulation would remain in effect until the 2015 Final Rule and the 2018 Supplemental Rule's effective date. The NCUA would continue to enforce the capital standards currently in place and address any supervisory concerns through existing regulatory and supervisory mechanisms
- The proposed rule would prohibit the GSEs from approving any credit score model developed by a company that has an ownership interest in a consumer data provider to alleviate concerns of unfair competition and potential vertical integration.
Comments due to NAFCU: July 12, 2019
Comments due to FHFA: July 26, 2019
NAFCU will send comments on behalf of its members to the NCUA by their deadline (July 26, 2019).