1,850 RBC letters and counting

NCUA staff yesterday morning said the agency had counted 1,850 comment letters so far, and was still processing letters, on its risk-based capital proposal – making this round already the largest number received on a proposed rule since 1995.

In 1995, NCUA received 1,300 comment letters in its first round of comments on a proposed corporate rule, which was out for a 120-day comment period. NCUA later issued a new proposal.

In its comment letter submitted Tuesday, NAFCU urged NCUA to withdraw its risk-based capital proposal or make significant changes, all outlined in the letter, and go out for a second round of comments on a new one. It has urged at least a three-year implementation period for any final rule.

NCUA Board Chairman Debbie Matz has been talking recently in the trade press and in the agency’s own newsletter about possible changes to the current proposal – in how risk weights are “calibrated,” through added clarity on the individual minimum capital requirements and more time for implementation than the 18 months proposed.

Matz is hosting three listening sessions in June and July where credit unions will be able to raise any issues they choose to raise. She has said the sessions will precede the issuance of any final risk-based capital rule.

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