Over the course of the next three weeks we will be releasing a three-part series completed by CU*Answers audit, legal, and compliance professionals addressing the NCUA’s recent revisions to the proposed Risk Based Capital rule. The series will first concentrate on a holistic view of why this rule is flawed, followed by a legal perspective. The goal of the series is to bring awareness to the changes and explain our opinion for why the rule should not become law.
Part 1 – The Holistic Argument: What history has taught us and what the future holds
Part 2 – The Holistic Argument cont.: Protecting the Cooperative model and what’s next
Part 3 – Analysis of the Law Behind the NCUA Risk Based Capital Rule
In the last round of commentary approximately 2,000 comments overwhelmed the NCUA resulting in a 450-page round-two rule to address these comments in detail. To drive the point home that the proposed RBC rule is damaging to our industry, we need to double that number in the next 70 days. To assist credit union leaders, staff, and members, we have created a comment engine that has been seeded with some of the more germane points of the white paper along with the ability to add your own.
Whether you decide to comment today or wait until you’ve read our three-part series, be sure to let the NCUA know how you feel about RBC2!