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NAFCU is seeking members' comments on the NCUA's advanced notice of proposed rulemaking on alternative forms of capital by April 25. That input will aid NAFCU in formulating its official comment letter to NCUA.

Comments are due to the NCUA by May 9.

The ANPR focuses on alternative capital federally-insured credit unions could use to meet capital standards. NAFCU has welcomed the ANPR and continues to be focused on the establishment of capital flexibility that helps credit unions.

NCUA, through the ANPR, is contemplating potential changes to its rule for secondary capital. Secondary capital is authorized only for low-income-designated credit unions and counted in a credit union's net worth ratio and risk-based net worth requirement under prompt corrective action standards. The NCUA is also considering whether to authorize credit unions to issue supplemental capital instruments that would count only toward the risk-based net worth requirement.

NAFCU continues to push for legislation that would create a fair capital system providing, among other things, access to alternative capital for all credit unions, regardless of charter type.