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April 21, 2014 – NAFCU, pointing to NCUA's video touting the importance of comments in response to its proposed risk-based capital rule, on Friday urgedthat NCUA either withdraw the proposal entirely or extend the comment period by 90 days.

"The rule as proposed will have unpredictable consequences for loan and share growth, as individual credit unions will need to adjust their balance sheets to meet the new requirement," said NAFCU Regulatory Affairs Counsel PJ Hoffman, in a statement.

"Given the potentially wide-reaching, negative ramifications of this rule, we would support withdrawing it," he continued. "If not withdrawn, NAFCU calls on NCUA to extend the comment period 90 days so that credit unions can digest the complexity of the rule and provide constructive feedback to NCUA."

NAFCU's position is that the proposed rule is disruptive and extreme, and will hurt the credit union industry. The association encourages members to send comment letters to NCUA with the message of "enough is enough" with regard to the continued rollout of new rules from the agency. Under the current deadline, comments are due to the agency May 28. NAFCU has prepared talking points for members on specific problems in the proposal, including:

• the proposal's risk weights for non-delinquent first mortgage real estate loans, investments and member business loans;
• the individual minimum capital requirement; and
• the rule's implementation period.

NAFCU has also put out an adjustable risk-based net-worth calculator to help its member credit unions see how the proposed rule would affect them.

The association is also encouraging credit unions to participate in NCUA's listening sessions this summer, where they can share their concerns about the proposal in person with agency board and staff members.