Next time you ask your members to speak up in support of credit unions — perhaps the next time the credit union tax exemption is targeted — look in the mirror.
Did you comment on the agency’s proposed risk-based capital rule, version 2? Whether you’re for it or against it, your comment will be counted, just like a vote, and turnout is crucial.
Participation is a core principle that defines the cooperative, member-owner model. Democratic governance makes credit unions unique, but only if the responsibility is exercised.
Silence Will Be Seen As Assent
Last time around in 2014, more than 2,000 comments were submitted and the regulator responded with a substantially revised, 450-page version. This time about 340 comments have been sent in.
Silence will be taken as assent for RBC #2; the unstated assumption will be that commenters on the first version believe the NCUA got it right this time.
And if credit union leadership — its CEOs, directors, CUSOs, and other industry stakeholders — don’t participate in the debate, how can we expect members to respond when there is a need for direct grassroots participation on this or other issues?
Comments Can Be Brief
Virtually all the logic and data have been submitted. The information sent to the NCUA is voluminous and thoroughly documented. Comments this time can simply state their position as to whether risk-based capital rule is good public policy for cooperatives: a simple yes or no.
For example, one credit union member, Leigh Anne Terry, stated simply, “If it takes 450 pages to explain why this rule is good for credit unions, it probably isn’t. Please withdraw it.”
Wright-Patt CEO Doug Fecher’s assessment is similarly short: “RBC is a solution that wouldn’t work, for a problem that doesn’t exist.”
The silence is deafening. Please consider breaking yours by April 27.