WASHINGTON—With the April 27 deadline for comments on the second risk-based capital proposal approaching, CUNA is providing new resources to encourage credit unions to weigh in.
Available on CUNA’s website, the resources include a "comment letter guide" with information regarding the need for and value of commenting on the plan and how to comment.
"We are asking credit unions to individually tell their stories to NCUA, so the agency understands that their rule will have real impact on real credit unions and their very real members," said Bill Hampel, CUNA chief policy officer.
CUNA has stated that the second proposal is a substantial improvement over its predecessor, but is still a “solution in search of a problem.”
"With reductions in many of the risk weights found in the original plan, and a reduction to 10% for the well-capitalized requirement, the second proposal is an improvement," reiterated Hampel.
Hampel noted that the areas still needing improvement—such as the additional "capital adequacy" requirement and the future treatment of interest-rate risk—are described in the comment letter guide.
“So it is imperative that credit unions stay engaged in this rulemaking process to have as much impact on proposal improvements as possible,” Hampel said.
NAFCU has already taken steps to help drive more comments. As it did during the first risk-based capital comment period—several weeks ago NAFCU provided on its website talking points its member CUs can use to shape their letters. The points include the issues NAFCU has found with the rule, and issues to consider, the trade association stated.
Carrie Hunt, NAFCU SVP/general counsel, explained that the talking points are not meant to create “cookie-cutter comments. Credit unions will add their own perspectives.”
NCUA on March 12 reported that 300 comment letters had been received. More than half had come through CU*Answers, which has joined with several other organizations on “Credit Union Voices,” an effort to generate more RBC comments. The original proposal drew more than 2,000 letters.