UPDATE: NASCUS Publishes Risk-Based Capital Scorecard
January 15, 2015 – As NCUA presented its revised risk-based capital rule at today's Board meeting, NASCUS has published an RBC "scorecard," which contains important information highlighting a few of NASCUS’ substantial and hard-fought wins on the rule. Please click here to access the scorecard.
January 15, 2015 – In a 2-1 vote at its Board meeting this morning, the NCUA presented its second risk-based capital (RBC) rule.
The proposed rule, which NASCUS filed extensive comments for during the first comment period, was reissued with a 90-day comment period.
NCUA’s amended proposal includes several major changes the National Association of State Credit Union Supervisors (NASCUS) fought to include on behalf of the state credit union system, including a longer implementation period, a higher threshold for “complexity,” removal of the individual minimum capital requirement provision, and revised risk weights for mortgages, investments, commercial loans, and credit union service organizations (CUSOs). NASCUS is carefully reviewing the 450-page proposal and will post a detailed analysis as it is completed.
NASCUS commends NCUA on its diligent and thoughtful review of stakeholder comments, and on the numerous beneficial changes that it has made to the proposal over the last several months.
Although NASCUS has lingering concerns with certain areas of the rule, including the concentration thresholds for real estate loans and exclusion of supplemental capital, the overall progress from the original proposal is very encouraging.
“It’s gratifying to see that NCUA took our recommendations to heart,” said NASCUS President and CEO Lucy Ito. “We are confident that with continued open dialogue, the remaining issues with the rule can be worked out.”
NASCUS looks forward to working together with NCUA to strengthen safety and soundness, eliminate unintended consequences, and perfect this landmark regulation for the credit union system.