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MCUA’s Comment Letter Voices RBC2 Concerns

On behalf of Missouri’s credit unions, the Missouri Credit Union Association (MCUA) submitted a five-page comment letter outlining several areas of concern with the National Credit Union Administration’s (NCUA) revised risk-based capital proposal (RBC2). The comment period closed on April 27. 

“While RBC2 is certainly an improvement, we still have questions regarding NCUA’s authority to establish a risk-based capital standard for the purpose of determining whether a credit union is well-capitalized,” says John Thomas, MCUA’s SVP of Regulatory Compliance. 

Please click here to view MCUA’s full comment letter.

MCUA is sharing the letter with Missouri’s Congressional delegation. All ten of Missouri’s U.S. Senators and Representatives sent letters to the NCUA addressing concerns about the original risk-based capital proposal and urging additional input. 

The Credit Union National Association (CUNA) reported that more than 1,900 comment letters were filed as of late Monday afternoon, which was close to the same number as were submitted on the original proposal.

It’s estimated that a finalized version of RBC2 may be available in late 2015.

A special thanks to Anheuser-Busch Employees’ Credit Union, Bothwell Hospital Employees Credit Union, St. Louis Community Credit Union and West Community Credit Union for submitting letters during the RBC2 comment period.