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Chantelle Sparks

Chantelle Sparks

NCUA Annual Report

Credit Card Debt

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Payments

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The direct immediate impact of the new CCULR/RBC rule requires credit unions to hold between $30 to $40 billion more in reserves.  These funds cannot be used for daily operations, such as expenses to increase member value or lower fee income or loan rates.

The new RBC/CCULR rule must meet two administrative procedural tests, as any other rule, when NCUA claims to be implementing a law.  The first was outlined in an earlier column: Was there substantial objective evidence presented to justify the rule?