RBC2: Once More, With Feeling

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


The comment period for the NCUA’s second version of its risk-based capital rule closes on April 27. That means we all have a month to get our act together and say something. Something. Anything.  

Why bother? Because if we want a regulatory process that protects the credit union movement and the member-owners who give it life, we must participate. It’s our duty.

Commented last time? Great. Thank you. Now do it again. If you don’t, the NCUA will interpret your silence as support for its revisions. Is that how you feel?

Didn't comment last time? No worries. Now’s your chance. My colleague Chip Filson thinks the “NCUA will count the votes for and against the rule, and compare the number who voted last time with the number who do so this time.” At this point, the number of “votes” is running about 90% behind last time, so do your part to even the score. Let the NCUA know this matters.

Not sure what to say? A lot of people are in the same boat. This is a seriously complex rule.  Trying to tackle its shortcomings is like trying to figure out how to eat a whole elephant. But one bite at a time is a winning strategy. 

Over the next few weeks, I'll offer some thoughts on this proposal, one bite at a time. I’ll write about what it represents, what’s wrong with it, and why commenting on it matters so much. I'll bet that somewhere, you'll find something you agree with.

At the very least, I hope you’ll be inspired to write. Your opinion matters. Your willingness to express it matters even more.

This is not the most important credit union regulation ever. It’s not existential, like the tax credit, or defining, like the Membership Access Act, but it impacts every single U.S. credit union, even those it was carefully designed not to impact.  

This is a special case. Every member of a financial cooperative has a stake in this, and every credit union leader should be heard on it. This is where we stand up and defend our right to a participatory, consultative, cooperative regulatory and supervisory system (the only kind, for what it's worth, that has ever worked effectively and efficiently on a sustainable basis).

Comment periods exist for a reason, even if it's just to participate in a process that depends on our participation. Please, take pen in hand, put finger to keyboard, dictate a memo … whatever works, just speak and be heard.

The email address is regcomments@ncua.gov. Now’s the time to make your voice count.

If you're interested, here's a link to my comment letter. Read it — then send your own.

Next up from Chris Howard: why the fight is far from over.


March 30, 2015


  • Once again NCUA is "Ready. Fire. Aim" as an M.O. Mr. Howard's comment letter uses data to support that there is no problem to be solved here. Further more, the burden of this regulation will incent more volunteer directors to throw up their hands and merge their viable CUs, in my 30 years' experience with CU's under $100 million in assets. Could the Bankers' Associations think of a better way to rid themselves of competition from fairly priced financial services than implementing this RBC requirement? Why should they lobby Congress when NCUA is doing all this for them and against consumers? Please read the proposed regulations as well as the comment letters and WRITE NCUA. If we don't do take action now, will there be enough CU people left to undo it? I have my doubts.
    Carolyn Warden, CCUE