NAFCU letter to House of Representatives urging support for H.R. 2769, the Credit Union Risk-Based Capital Study Act of 2015

The Honorable John Boehner        
U.S. House of Representatives       
Washington D.C. 20515          

The Honorable Nancy Pelosi
Minority Leader
U.S. House of Representatives
Washington D.C. 20515  

Re: Support H.R. 2769, the Credit Union Risk-Based Capital Study Act of 2015

Dear Speaker Boehner and Leader Pelosi:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only national trade association that exclusively represents the interests of our nation’s federal credit unions, I write to urge your support for bipartisan legislation introduced by Representatives Stephen Fincher, Bill Posey and Denny Heck – H.R. 2769, the Credit Union Risk-Based Capital Study Act of 2015.

This important legislation will require the National Credit Union Administration (NCUA) to take a more deliberate approach before it issues an unnecessary and costly Risk-Based Capital final rule. It should be noted that the legislation will not prevent NCUA from instituting new capital
requirements, but will require NCUA to thoroughly examine the myriad of significant concerns raised by the credit union industry through the 2,167 comments submitted on this proposed rule.

H.R. 2769 will require NCUA to conduct a study and report to Congress on whether the agency has the clear legal authority to prescribe separate risk-based capital thresholds for both “adequately capitalized” and “well capitalized” credit unions; the differences between capital standards for credit unions and other types of depository institutions; the rationale behind the risk-weights in NCUA’s proposal; and the impact the proposed rule will have on credit union capital cushions, lending and examinations. While NCUA has made some adjustments from its original 2014 proposal, the current proposal still poses significant concerns for credit unions and their members that must be addressed before any final rulemaking.

H.R. 2769, the Credit Union Risk-Based Capital Study Act of 2015, is an important step in ensuring that credit unions have an appropriate capital regime. For this reason, NAFCU urges your support for this legislation. If my staff or I can be of assistance or answer any questions, please don’t hesitate to contact myself or NAFCU’s Director of Legislative Affairs Jillian Pevo at 703-842-2836.


Brad Thaler
Vice President of Legislative Affairs

cc:  Members of the House of Representatives

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