ALEXANDRIA,Va.—The deadline for comments on NCUA’s revised risk-based capital proposal is now 30 days away.
Representatives of a group that is working to “galvanize” credit unions and other officials to submit comment letters are urging people to take a moment and do so, as reports are the number of comments on the revised proposal are running significantly below the more than 2,000 letters recieved on the original risk-based capital proposal.
The group Credit Union Voices, which is being supported by a number of organizations, including Callahan & Associates and CU*Answers, reported that prior to CUNA’s GAC earlier this month the agency had received 262 letters from 30 organizations. Through the efforts of Credit Union Voices, which included a booth at GAC, that number hasd risen to 338 letters from more than 97 organizations just after GAC. CU Voices’ booth allowed people to submit a comment on-site.
“We had a great deal of traffic at our booth – something like 25 people an hour – even though its location was off the main track and behind a curtain wall. More than 50 people submitted comment letters from our terminal,” said Jim Vilker, VP of professional services at CU*Answers. “Credit union CEOs and staff from all sizes of credit unions, trade association executives, member-owners, state regulators … so RBC II is an issue that attendees were concerned about. But while everyone knew about it, most of those we talked with had not filed a comment for the second rule. That needs to change, and quickly!”
Vilker stressed that there are fewer than 30 days to send in comments.
“The deadline for filing comments is April 27, Vilker said. “Credit unions and their supporters need to pick up the pace, he said “to meet the number of comments sent for the first round of RBC proposed regulation, about 75 letters a day need to be submitted.”
Problem Looking for A Solution
Chip Filson, Chairman of Callahan & Associates, agrees. “It doesn’t need to be technical or expansive; rather, a short letter on whether RBC is good or bad policy for our cooperative industry. Our analysis of the data and the comment letters suggests credit unions believe instituting an RBC rule is still not the right direction.”
In a statement, CU Voices said that many industry leaders say they believe responding to this rare, second comment period is critical because the rule sets a dangerous precedent for the credit union industry and would change the future of credit unions, as summarized by Doug Fecher, CEO of Wright-Patt Credit Union in Beavercreek, Ohio.
"To say that NCUA's revised RBC rule is a ‘problem looking for a solution’ is a too kind, since it presumes that if there were an actual problem, RBC II would be a reasonable solution,” he said. “I prefer to say it this way ... ‘NCUA's revised RBC rule is a solution that won't work for a problem that doesn't exist.’ "