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More Than 1,650 RBC2 Comments Filed by Friday: Deadline Today
Monday, April 27, 2015 6:45 AM

As of late Friday afternoon, credit unions, state credit union leagues, CUNA and other stakeholders had sent 1,654 comment letters on the National Credit Union Administration revised risk-based capital proposal (RBC2). The comment period ends at 11:59 p.m. (ET) today.

Cornerstone and CUNA believe the proposal is a solution in search of a problem, but should the NCUA proceed with the rule, a number of changes are necessary.

This includes:

  • Dropping the new proposed capital adequacy provisions, which are beyond net worth and risk-based capital ratio requirements;  
  • Reduction of a number of the risk weights;
  • Identifying "complex" credit unions on more than asset size, and the definition should only apply to credit unions of at least $500 million in assets;
  • Expansion of the conditions under which goodwill could be included in the risk-based capital ratio;
  • Minimizing the burden of expanding the call report for purposes of RBC2; and
  • Allowing credit unions to use supplemental capital in meeting risk-based capital requirements;  
  • Delaying implementation of RBC2 until 2021, to coincide with expected refunds from the Corporate Stabilization Fund.

Cornerstone urges all credit unions in the region to submit your comment letter today. If you have questions about the RBC2 proposal or crafting your comment letter, please visit the Cornerstone website at, or contact Suzanne Yashewski at (512) 853-8516 or