Any changes to risk-based capital requirements—including the proposed adoption of a complex credit union leverage ratio (CCULR)—requires a delay of the Jan. 1, 2022 RBC effective date, CUNA wrote to NCUA Thursday. CUNA submitted its comments on the CCULR proposal, which allows credit unions that meet certain criteria to opt into the CCULR framework.
CUNA also reiterated its long-standing position that the 2015 RBC rule is “functionally unnecessary” and will place significant burdens on credit unions at a significant cost to credit union members.
NCUA proposed the CCULR framework at its July meeting. A complex credit union that opts into the CCULR framework would not be required to calculate a risk-based capital ratio under the Oct. 29, 2015, risk-based capital final rule.
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