Final RBC rule on NCUA Board agenda

OCT. 8, 2015 -- The NCUA Board will consider a final rule on “risk-based capital” at its Oct. 15 meeting in Alexandria – what has come be known as “RBC2” after the board issued a second proposed rule on the subject earlier this year.

The second proposal included numerous modifications from the first, which was originally proposed in 2014. In its comment letter, NASCUS noted that the changes represented “a significant improvement over the original proposal.” However, NASCUS recommended “further refinement” to ensure that the final rule “is right-sized for the credit union system and does not place credit unions at a competitive disadvantage in the marketplace.”

NASCUS made more than a dozen suggestions for refinement, including recommendations for: adjustments to defined terms (such as “appropriate state official”); honing the “complexity asset proxy” to be consistent with the congressional mandate regarding risk-based capital; and including supplemental capital in the risk-based capital numerator (i.e., strengthen the utility of supplemental capital for credit unions).

The proposed rule has also been the target of congressional efforts to make the agency “stop and study” the impact of the bill on credit unions before implementing it (the Risk-Based Capital Study Act (H.R. 2769), sent last week by the Financial Services Committee to the full House for consideration. would do exactly that). Also last week, the measure’s three sponsors -- Reps. Stephen Fincher (R-Tenn.), Denny Heck (D-Wash.) and Bill Posey (R-Fla.) -- asked the agency to voluntarily conduct the study.

In response, Chairman Debbie Matz Thursday wrote to the three legislators that the agency would "compile a report to respond to your request shortly after the Board's consideration of a final rule on Oct. 15."

Also on the board’s agenda for the open meeting next week: a proposed rule on permissible investment activities – bank notes (Part 703.14), and delegations of authority, approval of community charter requests.

LINK:
NASCUS comment letter on RBC2

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