23 Reasons Credit Unions Should Care About RBC2

The deadline to submit comments about NCUA's risk-based capital proposal is April 27. This roundup of RBC2 commentary offers inspiration and suggestions for crafting a comment.


Today is the last day for comments on NCUA's revised risk-based capital proposal. The initial proposal generated more than 2,000 comments. It's important version two does the same.

Debating what to say?  The 23 articles below are dedicated to providing facts and inspiration. So read. Comment. And rest assured your comments will shape the context of the vote  ... and maybe even the outcome.

What Role Did The Practitioners Council Play In NCUA’s Revised Risk-Based Capital Rule?

If NCUA implemented the role of the practitioners in the spirit of member participation, then the precedent could be an important milestone in how the agency works with credit unions.

By Chip Filson
Jan 12, 2015


Will NCUA’s Revised RBC Rule Benefit From Banking Regulators' Experience?

A speech by the vice chair of the FDIC should be top of mind as the industry considers the new risk-based capital proposal.

By Chip Filson
Jan 12, 2015


What To Listen For When The NCUA Board Discusses The Revised RBC Rule

To craft an effective response, credit unions must understand how board members view the rule.

By Chip Filson
Jan 13, 2015


Rate Your Regulator

How did the three board members and NCUA fare during the open meeting in which the agency released the revised risk-based capital proposal?

By Chip Filson
Jan 16, 2015


The Secret Legal Opinions Behind Public Decisions

NCUA is setting an anti-democratic precedent in its repeated efforts to keep private the legal opinions about its public regulatory authority. RBC is one example. The CUSO rule is another. Will there be more?

By Chip Filson
Jan 20, 2015


Training Fleas And RBC

Escape the circus and live beyond the limits of the imaginary lid. Comment on the RBC rule.

By Chip Filson
Mar 02, 2015


NCUA: Here's What The FDIC Really Said

When will the NCUA pay attention to how the FDIC views risk-based capital?

By Chip Filson
Mar 04, 2015


What Does Fourth Quarter Data Mean For The Risk-Based Capital Proposal?

Year-end data clearly proves there is no capital problem or shortfall in the credit union system.

By Chip Filson
March 12, 2015


“Vote” On RBC By Commenting Now

Exercise your right and do the right thing for your members by commenting on the risk-based capital rule. It's your "vote." Make it count.

By Chip Filson
March 26, 2015


Speak Up Either Way On RBC

Yay or nay, the cooperative system needs your participation on matters of such consequence.

By Chip Filson
March 27, 2015


RBC2: Once More, With Feeling

Already commented once? Do it again. Haven't yet? Now's the time.

By Chris Howard
March 30


RBC2: It Ain't Over Yet

NCUA will assume it's all peachy-keen unless the agency hears from credit unions.

By Chris Howard
March 31, 2015


RBC2: Only One Mind To Change

Credit unions should focus their efforts on persuading NCUA board member Rick Metsger to change his mind on RBC.

By Chris Howard
April 2, 2015

Raising Alarm About Risk-Based Capital (VIDEO)

Callahan's research chief goes on the air with CUbroadcast to discuss why the NCUA board should vote against the agency's proposed risk-based capital rule and why credit unions need to lodge their comments now.


RBC2: This Proposal Is No Solution

The NCUA is proposing an invasive, possibly illegal solution to a problem that does not exist.

By Chris Howard
April 6, 2015


RBC2: Just Common Sense?

Systemic rules like RBC are always simplistic and inflexible, a kind of bureaucratic bludgeon.

By Chris Howard
April 6, 2015


RBC2: What Capital Problem?

The argument that existing capital regulations are ineffective just doesn’t hold water.

By Chris Howard
April 7, 2015


RBC2: Member-Owners Get Burned Both Ways

Reserves are different from capital, and with RBC2, credit union members pay the price.

By Chris Howard
April 13, 2015


RBC2: Questionable Claims

Much of the logic surrounding RBC2 is absurd, especially the idea that it offers any more protection than effective examination.

By Chris Howard
April 16, 2015


RBC2: NCUA Doesn’t Know What The Future Holds (And Neither Do I)

Like generals, regulators are always fighting the last war.

By Chris Howard
April 17, 2015


Is RBC2 The NCUA's Duty?

Rick Metsger says the NCUA has a duty to protect the insurance fund against "material risks."

By Chris Howard
April 19, 2015


RBC2: First, Do No Harm

This "fundamentally flawed" policy actually creates a capital problem.

By Chris Howard
April 20, 2015


RBC2: You Might Not Like What Comes Next

Legal battle and years of uncertainty could follow a final rule like this.

By Chris Howard
April 23, 2015


April 27, 2015



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