CreditUnionVoices

There are three ways to comment on the
NCUA's proposed risk-based capital rule

Fax

Fax

(703) 518-6391
Attn: Mr. Gerard Poliquin, Secretary, NCUA Board

Mail

Mail

Mr. Gerard Poliquin
Secretary, NCUA Board
1775 Duke Street
Alexandria , Va. 22314-3428
Ref: NCUA Risk-Based Capital Proposed Reg

"Quotes"

Analysis of the RBNW Rule Part 1

By Jim Vilker, NCCO, CU*Answers VP Professional Services, AuditLink

"Credit unions should consider resisting the Rule on holistic grounds, its questionable legal authority, and the detailed changes in the Rule itself. RBC should not become law."

"…this Rule will lead to less diverse credit union portfolios and create potentially dangerous concentrations caused by credit union adherence to the standards being proposed."

"In and of itself, this rule creates more risk than it proposes to control."

"Effective supervision is not rule making; it is intelligent supervision and patient reorganization when problems arise. This is lacking in our CU regulatory community today."

Analysis of the RBNW Rule Part 2

By Jim Vilker, NCCO, CU*Answers VP Professional Services, AuditLink

"Will this not force the industry into potential areas of investment and lending the credit union lacks experience with or industry wide concentrations that could be impacted by similar economic variables? In and of itself, this rule creates more risk than it proposes to control."

"The idea that passing a rule—the typical government reaction—can stop fraud, eliminate mismanagement and prevent external circumstances from decimating a credit union's market environment is wrong."

Analysis of the RBNW Rule Part 3

By Jim Vilker, NCCO, CU*Answers VP Professional Services, AuditLink

"As guidelines, the NCUA would have greater flexibility to take in consideration the field of membership of the credit union and its charter, and would help identify areas of potential risk without forcing a credit union to institute changes both potentially drastic and unwarranted in the institution’s balance sheet."

"The NCUA has to reach by arguing that the agency meets the regulation by creating a separate “well capitalized” tier, when the plain language of Section 216 refers only to “adequately capitalized credit unions.” The NCUA’s support is that the agency “could reasonably impose different degrees of protection” when the statute itself says no such thing."

The follwing are a sample of the comments filed in response to the first proposal in 2014. These will be updated as new comments are filed:

Gregg Stockdale at 1st Valley Credit Union

"This proposal is the equivalent of a push-broom with 2/3's of the teeth missing."

Daniel Popper at Archer Credit Union

"…an unrealistic burden on small rural credit unions like ours."