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RBC Proposal Dominates NCUA’s Listening Session

The Missouri Credit Union Association was on hand to represent Missouri interests at the National Credit Union Administration’s (NCUA) Listening Session in Chicago on July 10. As predicted, the Risk-Based Capital (RBC) proposal was the main focus of the discussion for the 160 people in attendance. After initial remarks from the regulators, credit union attendees had the floor to address their concerns.

“This session provided another opportunity for credit unions to ask questions and pose concerns regarding the various aspects of the Risk-Based Capital proposal,” says John Thomas, SVP of Regulatory Compliance for the Missouri Credit Union Association (MCUA). “In particular, credit unions implored NCUA to reconsider the risk weights.”

NCUA representatives at the listening session agreed that the risk weights should be reworked.

Many attendees also requested a re-issue and new comment period after NCUA has made revisions to the proposal—as a number of significant changes are anticipated. However, NCUA Chairman Debbie Matz said that unless significant changes take place regarding the intent of the rule, NCUA will not be required to offer a second comment period under the Administrative Procedure Act.

“The Risk-Based Capital proposal will become a reality, and the final regulation will be influenced by the two thousand comment letters and correspondence from members of Congress already submitted, as well as input from the three listening sessions,” says Don Cohenhour, MCUA president and CEO. “This emphasizes the importance of those comment letters from Missouri credit unions, and why MCUA worked with our Congressional delegation in sending letters addressing RBC. Thank you to 17 Missouri credit unions that wrote letters. I appreciate your efforts.” 

In addition, all eight of Missouri’s U.S. House members signed a Congressional letter and U.S. Senator Roy Blunt (R) sent an individual letter expressing concerns with the RBC proposal to the NCUA.

During the listening session, attendees also asked the NCUA to extend the proposed 18-month implementation period.

“Chairman Matz confirmed that the RBC rule will include a longer implementation period than the proposed 18 months,” says Cohenour. “The NCUA and credit unions will both need additional time. The NCUA requires time to prepare for the examination of credit unions’ compliance under this act and credit unions will need this time to adjust their business plans.”

Additional Resources

  • View MCUA's comment letter here.
  • Click here to visit CUNA's risk-based capital action center. 
  • NCUA will make recordings of the listening sessions available soon on its website
  • CUNA has posted clips of the Los Angeles listening session here

Caption: Approximately 160 representatives from credit unions and credit union leagues attended the listening session.