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Risk-Based Capital: Round 2 by the Numbers

Mon, May 4, 2015

Columbia, Maryland

It’s over! Monday, April 27 marked the last day in which the NCUA accepted public comments on its amended RBC regulations. This second comment period kicked-off in February after the regulations were published in the Federal Register as required by law. The final numbers submitted during Round 2 strongly suggest that credit unions and stakeholders in Maryland, District of Columbia, across the region and nationally continue to be concerned and have remained highly engaged on this important issue. 

Over 2,100 comments have been submitted and appears that this will slightly surpass the number of comments submitted during Round 1 (itself a NCUA record for comments). Maryland and District based credit unions continued with their strong engagement in this latest effort.  A total of 32 comments from MD and DC members, representing 30 individual credit unions have now been posted on the NCUA website…nearly 1/3 of our membership took action!  The Association’s advocacy team worked closely with members to craft and assist members as needed in submitting their respective comments under the deadline. The advocacy teams thanks all members who participated or considered doing so. 

This caps (but does not end) a process that began over 18 months ago when the NCUA first proposed RBC regs which most industry observers felt were unnecessary. The first round ended in May 2014. In addition, a joint Congressional letter at that time gathered 324 signatures almost evenly divided between Republican and Democrat which expressed concern for the proposed RBC regulations.  While this record number of comments during Round 2 is unlikely to force the agency’s hand for another comment period, it does speak to the ongoing concern and interest that CU stakeholders have in what the agency is doing and how it affects their members. 

As with Round 1, the Advocacy team has worked to engage members on this and other issues and will continue to do so. It cannot be said enough…only through forceful engagement by CU stakeholders did the NCUA feel the pressure to agree to a second comment period. The ‘process’ is not completely over because while the regs will move forward in the months ahead, agency leadership and different viewpoints among staff will also likely emerge in due course. This in no way means that the RBC regs will end but it does mean we must remain engaged and continue to make our case on those regulations that work as well as forcefully but respectively making the case why other regs do not.  Members and the advocacy team must continue to work together to weigh in, engage and affect the discussion.

For more information contact: Glen Cooney - VP, Advocacy & Legislative Affairs, 443-325-0775 gcooney@mddccua.org.