GAC is ideal opportunity for member comments on NCUA’s 2nd RBC comment draft

WASHINGTON, DC (March 3, 2015) — With more than 2,000 politically active directors, senior executives and credit union members attending CUNA’s Governmental Affairs Conference (GAC) March 7-12, it’s the right time to submit comments about NCUA’s risk-based capital (RBC) rule, Version #2. To facilitate responses, an alliance of credit union organizations is sponsoring an exhibit hall booth, Credit Union Voices, so members can file comments while at the Conference. The exhibit hall is open March 8-10, as posted in the GAC Exhibit Schedule.

NCUA’s first RBC proposal received more than 2,000 comments – the most responses posted on any single issue. As a result of concerns expressed by the credit union community, legislators and others, NCUA made hundreds of changes and issued a second proposed RBC regulation on Jan. 15, 2015. The new proposed rule has a 90-day comment period that ends April 27, 2015.

Chip Filson, Chairman of Callahan & Associates and one of the Voice’s organizers, cited three reasons for encouraging participation in this effort:

  • The 2,000-plus attendees at the GAC are among the most politically active and aware credit union volunteers, leaders and members.They know the issues. This is the time and place to act. The Voices booth will make it easy for commenters to put forth their assessments.
  • Commenters filed a record number of letters on NCUA’s first proposal. If only a few hundred members respond this time, NCUA could interpret a lack of activity as concurrence for the revised rule. The revision of the tactical details in RBC #2 – risk weightings, ratios and implementation periods – allows commenters to focus on the critical policy issues the rule raises for cooperatives.
  • The cooperative model relies on member participation. Of all the principles that distinguish credit unions, the most vital is that member-owners participate in the design of their institutions.

Grassroots involvement is a critical way credit unions demonstrate their power in the Washington political arenas. By demonstrating members’ concerns about this proposal, credit unions enable their supporters to speak up in Congress and among regulatory bodies.

Credit Union Voices will have computer terminals that link directly to NCUA’s comment page. Information and analysis will be available for those who wish to consult resources in preparing their responses.

According to Randy Karnes, CEO of CU*Answers, the rule is about more than RBC. “The risk-based capital rule is a test of the industry’s willingness to shape its own cooperative destiny,” said Karnes, an active supporter of CU Voices. “Apathy or inaction means we lose that capability. Rules like this require our full-throated engagement; the way they are implemented and executed can kill off future opportunities with the death of a thousand cuts.”

Karnes says every regulatory event can be a time to do something big for credit unions and the 100 million-plus members they serve.

“It can change the comment process or the board-documented debate,” he said. “That way, even the battles we lose or that initially get no attention add up to important issues people feel empowered to address in the future.”

Visit the Credit Union Voices booth at Exhibit No. 162, which will be open during all GAC exhibit hours. To review comments or learn more about the RBC issue, visit Credit Union Voices online.

About Credit Union Voices

Credit Union Voices is an alliance comprised of credit union organizations that are bringing attention to critical issues affecting the industry. Their mission is to provide information and education that encourage the credit union community to speak up on behalf of the 100 million-plus people who rely on their credit unions for financial services and support.

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