WASHINGTON (2/26/14, UPDATED 10:04 a.m. ET)--The risk-based capital rule proposed by the National Credit Union Administration at its February open board meeting--and hotly discussed by credit unions since--is scheduled to be published tomorrow in the Federal Register.
That publication, in a sense a formality, changes nothing but it is consider "constructive notice," meaning interested parties are now noticed that the rule or proposal exists and what its precise parameters and details are.
Often comment periods or effective dates aren't set until the Federal Register notification occurs.
For the risk-based capital rule that means comments will be due 90 days from tomorrow.
The Credit Union National Association urged the NCUA from the start to address credit unions' "deep-seated concerns" regarding the risk-based plan. In fact, CUNA President/CEO Bill Cheney encouraged the regulators earlier this month to hold public hearings on the plan.
Cheney noted that hearings would produce an official record of discussions between credit unions and NCUA leadership that, in addition to comment letters, could assist the NCUA board in determining the best path for proceeding on the rule.
CUNA also has produced a video segment on the steps for writing an effective comment letter on this issue. (See resource link.)