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In a new post on the association's CFO Network, NAFCU Chief Economist and Vice President of Research Curt Long detailed the NCUA's recent advanced notice of proposed rulemaking (ANPR) on risk-based capital (RBC). The NCUA approved the ANPR board’s January meeting and is seeking feedback on simplification of the RBC rule, scheduled to take effect in 2022.

The NCUA in 2019 approved delaying the implementation of its RBC rule by two years to Jan. 1, 2022, and NAFCU has led efforts to ensure credit unions and their members benefit from a modern capital regime, working closely with policymakers on Capitol Hill and at the agency. 

The ANPR proposes two approaches to simplify the RBC rule, which include.

• replacing the RBC rule with a risk-based leverage ratio (RBLR), which uses risk attribute thresholds to define “complex” credit unions; and
• adopting a complex credit union leverage ratio (CCULR) – which Long noted is “more in line with the community bank leverage ratio (CBLR)” – that would leave the 2015 RBC rule unchanged but allow eligible complex federally-insured credit unions to opt-in to the CCULR to meet the RBC requirements.

In the post on the CFO Network, Long provided background on the RBC rule and outlines how both approaches included in the ANPR would affect credit unions.

Comments on the ANPR are due to the NCUA 60 days after publication in the Federal Register. NAFCU encourages credit unions to offer feedback via the association’s survey on the ANPR; credit unions may also submit feedback by contacting Long.

In addition to providing members with insights into the RBC proposal, NAFCU sent a Final Regulation Summary breaking down the CFPB's final rule related to supplemental debt collection.

The final rule is in conjunction with the bureau’s final rule on consumer disclosures related to debt collection issued in December. The CFPB in October finalized its debt collection rule – which applies to third-party debt collectors and heeded several concerns NAFCU had flagged for the bureau in its comments on the proposal – and indicated it would issue a separate rulemaking for disclosures.

Member credit unions can subscribe to receive Final Regulation Summaries.