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The Advocate - Action Alert
Wednesday, April 16, 2014 8:00 AM

By now, all of you have heard about NCUA’s proposal to establish a risk-based capital rule for CUs. The deadline for submitting comments is May 28. Since NCUA has denied CUNA's request for an extension on the comment period, May 28 will be here before we know it. Your comment is urgently needed now.

We are aware of only six comment letters sent so far from Cornerstone credit unions, and as the largest league in the country, we are behind the curve. Help us catch up! A capital requirement is the pivotal issue that links all CUs together. Regardless of whether the proposal adversely impacts you today, this is an issue that could ultimately affect all CUs.

Important points to keep in mind:

  • CUs will basically fall $7.3 billion short of their current capital amounts. That’s because credit unions tend to maintain a buffer beyond what is required to be well capitalized. Under NCUA’s proposal, that buffer will be reduced by $7.3 billion. In order to restore that buffer, credit unions will have to consider increasing loan rates, reducing savings interest, or changing their services by reducing mortgage loans and MBLs. All of that is bad for CU members.
  • This proposal covers CUs with assets over $50 million. Many CUs whose assets are currently between $40 million and $50 million will exceed the $50 million level in just a few years.
  • NCUA will have the authority to impose even higher capital standards on a case-by-case basis. What if it’s your CU?
  • CUs must be in compliance with the new capital requirements 18 months after the rule takes effect. Banks have nearly nine (9) years to comply with the new Basel III capital requirements.

NCUA must hear from CUs on this important issue. We can’t send form letters or postcards; they will not have an impact. But personal letters from CUs can cause the agency to reexamine and modify this proposal. Take a few minutes this week to write a short letter to NCUA telling them how you feel about this proposal.

Roadshow Meetings

Need more help? Join us as we take this issue on the road. We'll discuss NCUA's risk-based capital proposal with you in depth and help you draft your comment letter. 

Friday, April 18, 10:00-11:30 am
Cornerstone Credit Union League
1122 Colorado, Suite 1307
Austin, TX 78701

If attending, RSVP to Charlotte Spencer at

Tuesday, May 6, 10:00-11:30 am
Brookstreet BBQ
10705 Westheimer Road
Houston, TX 77042

If attending, RSVP to Charlotte Spencer at

Tuesday, May 13, 12:00-1:30 pm
Cornerstone Credit Union League
631 East Hill Street
Oklahoma City, OK  73105

If attending, RSVP to Charlotte Spencer at

If you need assistance writing your letter, contact Suzanne Yashewski, Cornerstone’s SVP of Regulatory Compliance at: And as always, please copy Suzanne on any correspondence you do send.

For more information, please visit our Cornerstone Comment Calls page or CUNA’s Risk-Based Capital Action Center for the latest information on the proposal and to access the CUNA calculator.