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CUNA's RBC blog will focus on the potential issues, what leaders throughout the credit union system are saying about them, and will provide a forum for CUNA members to discuss RBC issues with each other and with CUNA staff.
Posted January 26, 2015 by CUNA Regulatory Advocacy

CUNA was instrumental in the National Credit Union Administration (NCUA) revising their risk-based capital proposal.

Posted January 26, 2015 by CUNA Regulatory Advocacy

CUNA's Deputy General Counsel, Mary Dunn's power point slides from today's webinar are now available.

Posted January 26, 2015 by CUNA Regulatory Advocacy

CUNA's Chief Policy Officer, Bill Hampel's power point slides from today's webinar are now available.

Posted January 26, 2015 by CUNA Regulatory Advocacy

Here you will find a copy of Larry Fazio (The NCUA's Director of Examination & Insurance) power point slides from today's webinar.

Posted January 26, 2015 by Claudia Grabow

The NCUA has signaled that the agency is interested in exploring the use of supplemental capital for credit unions.  First, Chairman Debbie Matz announced that the agency will be forming a credit union working group to explore the use of supplemental capital.  Second, although RBC 2 does not allow for supplemental capital, the proposal does ask six specific questions as to the use of supplemental capital.

Posted January 23, 2015 by CUNA Regulatory Advocacy

Our analysis of NCUA's RBC2 continued throughout the week as we prepare for Monday's webinar on the agency's proposal. If you haven't registered for the Jan. 26 event, please register here. I will host the webinar alongside Chief Policy Officer Bill Hampel, Deputy General Counsel Mary Dunn and NCUA Director of Examination and Insurance Larry Fazio. 

Posted January 21, 2015 by CUNA Regulatory Advocacy

Here you will find a memo sent from CUNA President CEO, Jim Nussle, and COO & Chief of Staff, Richard Meade to the Board of Directors regarding their legal opinion on The NCUA's Revised Proposed RBC Rule.

Posted January 20, 2015 by CUNA Regulatory Advocacy

There's still time to register. The Credit Union National Association's staff continues to pour through the 500-plus page revised risk-based capital (RBC) proposal that was issued by the National Credit Union Administration Thursday, and will detail their findings in the webinar scheduled for Jan. 26. 

Posted January 20, 2015 by CUNA Regulatory Advocacy

With the release of the National Credit Union Administration's revised risk-based capital proposal (RBC2), credit unions should be prepared to analyze the proposal and engage in the regulatory process, says Credit Union National Association President/CEO Jim Nussle. The CUNA leader sent a letter to members of the U.S. Senate and House Friday with information about the proposal, as well CUNA's stance on the revised plan. 

Posted January 16, 2015 by CUNA Regulatory Advocacy

According to CUNA's analysis, nearly 200 credit unions would have been classified as only adequately capitalized in the first RBC proposal. NCUA reports that with RBC2, those numbers will be cut to 19. CUNA will conduct its own analysis of

Posted January 16, 2015 by CUNA Regulatory Advocacy

For the latest information and analysis on RBC2 I encourage you to check the RBC2 resource page on CUNA's website. Resources there include our top priorities, videos, NCUA and other resources.

Posted January 16, 2015 by CUNA Regulatory Advocacy

The credit union movement got a first look at the revised risk-based capital proposal from the National Credit Union Administration (NCUA) yesterday. While we remain unconvinced that this risk-based capital approach is necessary and have questioned the agency’s legal authority to implement some parts of the proposal, there is much good news to report: The agency addressed most of the changes that CUNA had advocated for on behalf of the credit union system. 

Posted January 16, 2015 by CUNA Regulatory Advocacy
CUNA sends letter to the member of the House and the Senate regarding initial reaction to NCUA's Revised Risk-Based Capital Proposal.
Posted January 16, 2015 by CUNA Regulatory Advocacy

While the National Credit Union Administration's revised risk-based capital (RBC2) proposal contained many changes wanted by the Credit Union National Association, the organization believes further changes are needed.

Posted January 16, 2015 by CUNA Regulatory Advocacy

Though the National Credit Union Administration board approved the agency's revised risk-based capital proposal to be issued for a 90-day comment period, the board members themselves have varied opinions about the plan.

Posted January 15, 2015 by CUNA Regulatory Advocacy

A Credit Union National Association video of today's National Credit Union Administration open board meeting discussion of a new risk based capital plan for credit unions is now available below.

Posted January 15, 2015 by CUNA Regulatory Advocacy
NCUA Vice Chairman, Rick Metsger, releases his statement on the proposed RBC rule.
Posted January 15, 2015 by CUNA Regulatory Advocacy
NCUA Chairman, Debbie Matz, releases her statement on the proposed RBC rule.
Posted January 15, 2015 by CUNA Regulatory Advocacy
NCUA Board Member, J. Mark McWatters, releases his statement on the proposed RBC rule.
Posted January 15, 2015 by CUNA Regulatory Advocacy

This morning, NCUA voted 2-1 to release for comment a second version of its Risk-Based Capital Proposal. This re-issued proposal (RBC2) includes substantial changes from last year’s version. Here’s what you need to know.

Posted January 15, 2015 by CUNA Regulatory Advocacy
Hear what the NCUA board members have to say about the revised RBC proposal.
Posted January 15, 2015 by CUNA Regulatory Advocacy

The National Credit Union Administration board just voted to put out a revised risk-based capital plan for credit unions for a 90-day comment period, which will begin when the proposal is published in the Federal Register.  The hundreds of pages of documents are packed with revisions from the agency's original and highly criticized plan launched almost exactly a year ago on Jan. 23.

Posted January 15, 2015 by CUNA Regulatory Advocacy

Mark McWatters concluded his statement regarding the second RBC proposal, will not support the proposal.

Posted January 15, 2015 by CUNA Regulatory Advocacy

NCUA drops interest-rate risk (IRR) from the second proposed RBC rule in response to comments from credit unions, credit union leagues and CUNA. 

Posted January 15, 2015 by CUNA Regulatory Advocacy

CUNA President and CEO Jim Nussle released the following statement immediately following the NCUA board unveiling its revised risk-based capital proposal today at its January board meeting.

Posted January 15, 2015 by CUNA Regulatory Advocacy

Documents from the NCUA Board Meeting are now available to view. 

Posted January 15, 2015 by CUNA Regulatory Advocacy

The first NCUA Board Meeting of 2015 will begin at today, January 15th at 10AM Eastern. 

Posted January 14, 2015 by CUNA Regulatory Advocacy
The new risk based capital proposal is set to be considered by the NCUA Board on January 15. This is one of the most important proposals credit unions will face in 2015 and we understand it is lengthy and detailed.
Posted January 13, 2015 by CUNA Regulatory Advocacy

Today NCUA posted its January 15 Board open meeting agenda. As NCUA had previously indicated, a new proposed risk-based capital rule is on the agenda for consideration by the Board at the meeting. CUNA had raised a number of key issues with the first proposal and will be scrutinizing the new one to see how the agency addresses the major issues that impact credit unions the most.  

Posted January 13, 2015 by CUNA Regulatory Advocacy
It's official. Credit unions will get their first look at a revised regulatory risk-based capital (RBC) plan from the National Credit Union Administration next Thursday. The new plan will be unveiled at the Jan. 15 open board meeting, according to an agenda released by the agency Thursday.
Posted May 14, 2014 by CUNA Regulatory Advocacy

NCUA Board Member Michael Fryzel has responded to CUNA’s request to extend the RBC comment deadline beyond May 28.  Mr. Fryzel explicitly stated that he supported extending the comment deadline and would have voted to provide more comment time if the issue was put up for vote at an NCUA board meeting.  That is not at all likely and the comment deadline remains May 28, but it was good to hear his support. 

Posted May 09, 2014 by CUNA Regulatory Advocacy
CUNA’s efforts to achieve a better risk based capital rule got a huge boost this week from current and former members of Congress.  

Former Senator Alfonse D’Amato (R-N.Y.), who chaired the Senate Banking Committee during the HR 1151 battle and led the development of the prompt corrective action sections of the Federal Credit Union Act, wrote to NCUA Wednesday outlining how the agency would exceed its legal authority if it adopted  the RBC proposal.
Posted May 02, 2014 by CUNA Regulatory Advocacy
NCUA’s comment deadline to submit RBC comments to the agency is rapidly approaching.  We have formally asked twice for an extension of the comment  period – which we think is a reasonable request given the magnitude of the proposal -- but have been denied twice.  The deadline for comments to the agency remains May 28.
Posted April 25, 2014 by CUNA Regulatory Advocacy
Last week while discussing RBC calculators we mentioned that your capital conclusions will be worthless if an NCUA examiner decides that your credit union needs additional capital.  NCUA calls this proposed requirement individual minimum capital requirements (IMCR).  NCUA’s RBC proposal states that “NCUA may establish increased individual minimum capital requirements upon its determination that the credit union’s capital is or may become inadequate in view of the credit union’s circumstances.”
Posted April 23, 2014 by CUNA Regulatory Advocacy
Most readers now know that NCUA’s RBC proposed rule applies to “complex” credit unions, which NCUA defines as any federally insured credit union with more than $50 million in assets.  Why did NCUA choose to define “complex” based on asset size?  From our perspective, this is overly simplistic.  It is business decisions, operations, activities and portfolios that make a credit union’s operations complex, not simply its assets.  The definition of “complex” should rely on factors that are actually related to risk.  
Posted April 16, 2014 by CUNA Regulatory Advocacy
Which risk-based calculator is your credit union using to model the impact of the RBC rule?  As we have discussed previously, NCUA has made available to the public a risk-based capital calculator, but did you know that CUNA also has a risk-based capital simulator available to members, too?  Which one should your credit union use?  Both!  
Posted April 11, 2014 by CUNA Regulatory Advocacy

Editor's Note: The below post was written by Lou Gill, Secretary and Director of Chartway Federal Credit Union:

I have just completed my first letter to the NCUA.   In the past I have always let our CEO take the lead on comment letters addressing proposed regulations.  But, this Prompt Corrective Action Risk-Based Capital (RBC) proposed regulation is different.

Posted April 07, 2014 by CUNA Regulatory Advocacy

CUNA wants to leave no stone unturned in our pursuit of a vastly improved risk based capital proposal.  That is why last week CUNA Deputy General Counsel Mary Dunn filed a comment letter with the Office of Management and Budget (OMB) detailing concerns regarding NCUA’s estimates of the burdens the proposal would create.    CUNA will be filing its detailed comments to NCUA on all aspects of the proposal in the coming weeks.

Posted April 03, 2014 by CUNA Regulatory Advocacy

Thursday, a NCUA media release reminded credit unions and other stakeholders that they have until May 28 to submit comment letters to the agency on its risk based capital (RBC) proposal.  We commend the agency for reminding credit unions, leagues, and others of this important deadline. We are also glad the agency is taking the calculator down after May 28.  The calculator, which indicates a credit union’s net worth and RBC ratios as well as prompt corrective action classification under the proposal, should not be accessible to the public, as it is now.  However, despite our concerns that some credit unions will be inadequately capitalized under the proposal, the calculator was not blocked and any member of the  public can go onto NCUA’s website and use the calculator to determine any federally insured credit union’s capital adequacy.

Posted April 03, 2014 by CUNA Regulatory Advocacy

With 56 days left to comment credit unions and credit union members have been busy telling NCUA what they think of the RBC proposed rule.  Based on the initial comments that NCUA has posted to their website, it looks like there will be little support for the RBC rule as proposed.  Many credit unions have told the story of the rule from their perspective, focusing on how the rule will limit lending or growth of the credit union movement.  Some organizations like NACUSOhave focused on risk weightings, such as for CUSO investments.  Although the reasons may vary, the message is the same: NCUA needs to withdraw or substantially modify this proposal. 

Posted April 02, 2014 by CUNA Regulatory Advocacy

NCUA’s proposed Risk-Based Capital rule would be the most detrimental, wide-reaching regulatory change affecting credit unions in years.  If adopted,  credit unions with assets greater than $50 million would need to increase the amount of capital held in order to be well capitalized, and could face burdensome risk weightings that would serve as a disincentive for member business and mortgage loans, and long-term investments.  CUNA’s calculations project that up to $7.3 billion in additional capital would need to be held.  These changes are being proposed after the existing capital rules allowed credit unions to survive the greatest economic disaster since the great depression.  We think this proposal is a regulation in search of a problem, plain and simple. 

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