Exercise your right and do the responsible thing for your members by commenting on the risk-based capital rule. It's your "vote."
Cooperatives rest on democratic governance. On the idea that member-owners will participate in the direction and activity of their credit union.
RBC #2 is a direct test of credit union leaders’ willingness to act on this principle. For the second RBC proposal is not about technical details — such as improving almost 100 risk ratings — but simply, whether or not RBC is good public policy for credit unions.
Your Comment Is Your Vote
The comment need only be a simple “yes” or “no” vote filed with the agency by April 27. Please send one, and send it now, to regcomments@NCUA.gov.
Every vote will be posted along with the commenter’s organization. If a commenter wants to add an explanation for their vote, that is certainly permitted.
Voting is what makes cooperative democratic governance special. But a responsibility not used is a freedom lost.
The NCUA will count the votes for and against the rule. They will compare the number who voted the first time with the number who participated the second. Abstaining on this second proposal will be interpreted as “we got it right this time” by the NCUA.
Others will be watching the vote as well — the credit union press, the Congress, the public — but most importantly your peers. These comments are public. They're online. Right here.
As of December 2014, 1,520 credit unions had assets of more than $100 million. They are directly subject to this rule. Yet as of today, fewer than 10 of these credit unions had “voted” in this second round.
Representing Members’ Best Interest
For a CEO who wants to provide leadership for the board and more importantly represent the best interests of the membership, voting on this proposal (for or against) is vitally important.
In fact, it’s the most important action that a CEO can take to demonstrate confidence in the democratic values at the core of the cooperative.
This is a direct action opportunity. Credit unions can’t vote for NCUA board members, for legislation going through Congress, for or against new CFPB rules.
But commenting on RBC# 2 — or staying silent — will have immediate consequences for the entire cooperative system by influencing the fate of this regulatory initiative.
Take A Public Stand
Voting is a public stand. Griping about the rule privately, or in letters to the editor, or opting out by saying this is a “done deal” is a failure of leadership at a potentially critical point in the design of the cooperative system.
Relying on someone to “lobby the final rule” behind the scenes is defaulting on the public voice that ultimately moves decision makers.
Time is running out. Filing comments is even easier than going to a voting booth. You can mail them or email them. The NCUA has a comments page on its website describing how, and includes a video from Chairman Debbie Matz on how to write an effective comment.
Tracking the Ballots
Callahan & Associates will be charting and publishing the total comments for the next four weeks. Vote early, vote often, and urge your board members, employees and members to vote, too. What is at stake is the ability of credit unions to determine their members’ future.