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RBC2 Comment Efforts before April 27 Deadline
Friday, March 27, 2015 6:40 AM

With 22 working days left until the comment deadline for the risk-based capital proposal (sometimes known as RBC2), Credit Union National Association is providing new resources to encourage credit unions to weigh in.

The deadline to submit comments is April 27.

"With reductions in many of the risk weights found in the original plan, and a reduction to 10 percent for the well-capitalized requirement, the second proposal is an improvement," says Bill Hampel, CUNA chief policy officer.

However, Hampel emphasizes that there are still significant problems with the proposal, particularly as it relates to an additional "capital adequacy" requirement, and the future treatment of interest-rate risk so it is imperative that credit unions stay engaged in this rulemaking process to have as much impact on proposal improvements as possible.

As part of its new resources, CUNA has developed a "comment letter guide" with information regarding the need for and value of commenting on the plan and how to comment. It also lists a number of issues credit unions may wish to address.

Cornerstone Credit Union League SVP Regulatory Compliance Counsel Suzanne Yashewski says, "I strongly urge credit unions to comment on the revised risk-based capital proposal again because comment letters from credit unions are the best way to insure that the needed improvements to the proposal are made."

Yashewski adds that credit unions have an excellent resource on the Cornerstone website here, and that she is always available to help.