A gimmick worth using

by. Henry Meier

Kudos to Nicholas Ballasy of CU Times for getting to the heart of the matter in his video interview with Chairman Matz regarding why she has rejected calls from the trades for extending the comment period for the Risk Based Capital proposal. When she described the proposal as a “gimmick” and “delaying tactic,” he followed up by asking her if the three listening sessions she will be holding across the country will be part of the official comment period record. The answer: No, because under the Administrative Procedures Act evidence can’t be added once the comment period has ended.

Say What? Doesn’t that suggest that, given this very unique set of circumstances, an extension of the comment period would be more than a gimmick? If NCUA can’t legally take the comments it gathers from its listening sessions into account, then why is it having them? Either NCUA is going to take into account the comments and concerns of credit unions, or it is not.

I think having a public dialogue on this proposal is a great idea. This is the type of regulation that everyone says they agree with in theory. What a true dialogue could do is make people realize that there are trade-offs in proposals like this. Not every credit union is going to be a winner. There is some give and take that simply can’t be reflected in comment letters, as important as they are.

So, why not make these meetings part of the official record? I believe Chairman Matz is committed to making this the best proposal possible. Why not all work from the same public record when it comes to determining which risk-based capital framework is most appropriate for credit unions?

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