Aug. 2, 2018


NASCUS commends NCUA for delaying the rule on risk-based capital for one year, and for raising the rule's applicability threshold, but also urges the agency to work with state regulators during that year to develop a supplemental capital framework for insured credit unions."

ARLINGTON, Va. – This morning, the NCUA presented a proposal to delay implementation of its risk-based capital (RBC) rule for a year until January 2020.  

The rule was issued with a 30-day comment period. It follows RBC-1 and RBC-2 on which NASCUS filed extensive comments.  

NCUA’s proposal includes changes NASCUS sought to include on behalf of the state credit union system, including a longer implementation period and a higher threshold for “complexity.” NASCUS is carefully reviewing proposal and will post a detailed analysis as it is completed.

NASCUS President and CEO Lucy Ito issued the following statements in response to today’s developments:  

  • On delaying the implementation 
    “NASCUS commends NCUA for delaying the rule’s implementation until January 1, 2020. The development of risk-based capital requirements for credit unions is a complicated undertaking that will have an enormous impact on how credit unions operate, the products and services available to members, the types of information sought by regulators, and the costs of compliance.  NCUA, itself, needs time to develop guidance for examiners and credit unions; and, examiners and credit unions, in turn, need the additional time to prepare for compliance.”
  • On the raising the applicability threshold to $500 million 
    “NASCUS is pleased to see that NCUA took our recommendations to heart and is proposing to raise the threshold to $500 million.  At this threshold, NCUA would be able to ensure smooth implementation of the rule without threatening the viability of smaller institutions. NASCUS is carefully analyzing how raising the threshold for “complex” credit unions would impact individual credit unions and the broader credit union system.”
  • On not including supplemental capital 
    “It is disappointing that NCUA has again declined to include supplemental capital for non-low income consumer credit unions within the proposed risk-based regulatory framework. Supplemental capital has a key role in protecting the NCUSIF and bolstering the safety and soundness of the credit union system.  NASCUS will continue to engage with the Agency to secure this valuable tool for credit unions ahead of the next financial crisis that strikes the credit union system.”  Ito added, “NCUA previously committed to promulgate a supplemental capital framework in conjunction with RBC. NASCUS urges NCUA to use the delayed implementation to consult and coordinate with state regulators to develop a regulatory supplemental capital framework for insured credit unions.”

Information Contact:
Shelton Roulhac, Vice President, Communications,  or (703) 528-5974

The National Association of State Credit Union Supervisors (NASCUS) is the primary resource and voice of the state governmental agencies that charter, regulate and examine the nation’s state-chartered credit unions. NASCUS membership is made up of state-chartered credit unions, state regulators and other supporters of the state credit union system. NASCUS is the only organization dedicated to the defense and promotion of the state credit union charter and the autonomy of state credit union regulatory agencies.