ALEXANDRIA, Va.—Contrary to some predictions that apathy would mute response, feedback to NCUA’s revised risk-based capital proposal could exceed that of the first risk-based plan.
NCUA reported that comments on its revised risk-based capital proposal topped 1,800 by noon Monday, and CUNA believes feedback this time may surpass last year’s 2,100-plus record total for any previous comment period.
Some had forecast that many credit unions, having already commented on the first proposal, along with much of the feedback incorporated into the revised plan, would combine to limit the number of credit unions offering comment the second time around.
But both NAFCU and CUNA emphasized that the large number of comments to both proposals make it clear there is a high level of CU concern with the rule.
Bill Hampel, CUNA’s chief economist and chief policy officer, said that as of late last week CUNA began to believe that this round’s letters could surpass total comments from round one. “By tonight we could exceed the comments from the first RBC proposal, which is an indication of the interest the second proposal has raised among credit unions and the actions they have taken to comment on it,” Hampel said Monday morning.
NAFCU Vice President of Legislative Affairs Brad Thaler told CUToday.info that the “widespread interest and concerns” with the latest proposal, indicated by all the comments, supports that the agency should “withdraw the proposal and seek legislative solutions that would allow a true risk-based capital system for credit unions.”
“We believe that all these letters indicate the rule is problematic and that the agency should now take a step back,” said Thaler.
Both NAFCU and CUNA said in their comment letters that NCUA should withdraw the rule due to its negative impact on credit unions. But if that does not happen, both trade associations agree that it will take time—late this year or early in 2016—for a final rule to appear, due to NCUA reading and responding to another landslide of comments.
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