Primary capital is equity whether it is owned by stockholders, as in a bank, or it is the net worth of retained earnings, as in a credit union. The difference is that banks can issue, buy, and sell their equity. Credit unions cannot.
Secondary capital is subordinated debt. No matter what name it goes by — secondary, supplemental, Tier II — and no matter what its terms, it is all some form of subordinated debt. Various names indicate different regulatory structures, but fundamentally, they are distinctions without any real difference.
Capital itself is an indispensable foundation for the safe, sound, responsible management of every financial institution. It serves as a cushion for operations, a catastrophic loan-loss reserve, and a bulwark for the insurance fund.
Capital is not a tool for active risk management. Even for banks, it is too inflexible, inefficient, and expensive to be effective in this role. This is a key reason why the Basel risk-based capital model has never worked well and why leading bank regulators are moving away from it.
Capital is even less-suited to a risk management role for credit unions because most can only raise capital slowly through retained earnings. Banks, at least, have myriad ways of raising money fast.
This means RBC is a bad idea for credit unions no matter how the NCUA revises its proposal, and regardless of whether it includes access to supplemental capital.
Supplemental capital is a powerful potential tool, and if the NCUA continues to push for an RBC rule, universal access to supplemental capital for natural person credit unions is not only likely, it is necessary. But it won’t be without risk and difficulty.
On a practical basis, credit unions will never be able to compete with banks and private companies in the subordinated debt market, so supplemental capital will always be over-priced. To some extent, this is probably due to the NCUA’s arcane rules — which it promises to tweak — but for the most part it has more to do with the very nature of credit unions.
As member-owned cooperatives, credit unions don’t really play in the securities markets. In addition, they function and are governed differently than banks and use a different lexicon. Markets thrive on volume, homogeneity, and familiarity. Credit unions fail on all three counts, so it will be tough to interest traditional investors in credit union paper regardless of the other factors.
On a political basis, having the power to raise supplemental capital by issuing subordinated debt will just make credit unions “look” more like banks and increase pressure on Congress to terminate the tax exemption.
Credit unions are in this pickle because the political price for CUMAA was bank-type Prompt Corrective Action rules that subject cooperatives to an ill-fitting, stock-based regulatory structure. It is a damning legacy of political expediency triumphing over logic and rationality. And it is a perilous path to be contemplating again.