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Deadline TODAY for Submitting Comments on Risk-Based Capital 2.0
Monday, April 27, 2015 7:00 AM

RBC2 Deadline

Can you spare 15 minutes on behalf of credit unions? We're in the final stretch of the comment period, and today is the last day to submit your letters to the National Credit Union Administration regarding the critical risk-based capital 2.0 (RBC2) proposal.

To date, Cornerstone credit unions have submitted 18 comment letters. Last year at this time, we had submitted 84 to the original RBC proposal and those letters were included in the 2,000 that NCUA received. The volume of comment letters is the reason NCUA decided on more review time and credit unions were granted a second comment period. Today, we must continue to press our case so that NCUA has no doubt about our resolve to ensure modifications are made to this critical proposal.

Please act now.

Cornerstone Credit Union League SVP Regulatory Compliance Suzanne Yashewski has submitted Cornerstone's official comment letter. In her letter, Yashewski outlined specific items of concern to credit unions, including:

  • No Need and No Authority for Rule
  • Definition of Complex Credit Union
  • Risk Weights
  • Treatment of Goodwill
  • Capital Adequacy Plan
  • Supplemental Capital
  • Extension of Compliance
  • Interest Rate Risk

Yashewski reminded NCUA that its job is to regulate credit unions so that they can thrive and grow; the NCUA should not be managing the credit union balance sheet. She urged NCUA to withdraw the proposal because it exceeds NCUA’s statutory authority and is fundamentally flawed in a number of areas. Alternatively, should NCUA proceed, she urged substantial improvements as described in her letter.

You can view the entire Cornerstone comment letter here.

Cornerstone would like to gratefully acknowledge the following credit unions who have already submitted their letters to NCUA:

  • A+ FCU
  • Abilene Teachers FCU
  • Amarillo Community FCU
  • American Airlines FCU
  • Amplify FCU
  • Educators CU
  • Firstmark CU
  • Generations FCU
  • Members Choice CU
  • Oklahoma Employees CU
  • People's Trust FCU
  • Randolph-Brooks FCU
  • Rio Grande Valley CU
  • San Antonio FCU
  • Security Service FCU
  • Southwest Airlines FCU
  • Tinker FCU
  • Wichita Falls Teachers FCU

Need more information and resources? Head over to CUNA's RBC page.

If you have questions about the RBC2 proposal or crafting your comment letter, please see our website at, or contact Suzanne Yashewski at (512) 853-8516 or