CCUA Survey on Capital Adequacy

Responses due by October 8, 2021

In the Association’s continuing effort to represent the interests of member credit unions before the National Credit Union Administration (“NCUA”), your input on a pending proposal is requested using its online survey 07-21 relative to capital adequacy for complex credit unions and risk based capital (“RBC”).

NCUA has issued a proposed rule that would provide a simplified measure of capital adequacy for complex credit unions which are defined as those with total assets greater than $500 million. Under the proposed rule, a complex credit union that maintains a minimum net worth ratio, and that meets other qualifying criteria, will be eligible to opt into the complex credit union leverage ratio (“CCULR”) framework. The minimum net worth ratio would initially be 9% on January 1, 2022, and then gradually increased to 10% by January 1, 2024. A complex credit union that opts into the CCULR framework would not be required to calculate an RBC ratio under the 2015 Final Rule. A qualifying complex credit union that opts into the CCULR framework and that maintains the minimum net worth ratio would be considered well capitalized. Under the proposal, a qualifying complex credit union that has adopted the CCULR framework and then subsequently no longer meets the qualifying criteria, would be required, within a limited grace period of two calendar quarters, either to once again meet the qualifying criteria or comply with the RBC ratio requirements.

The proposed rule also seeks to make several amendments to the 2015 Final Rule, including addressing asset securitizations issued by credit unions, clarifying the treatment of off-balance sheet exposures, deducting certain mortgage servicing assets from a complex credit union’s RBC numerator, updating several derivative-related definitions, and clarifying the definition of a consumer loan.

The proposed rule may be found at Capital Adequacy: The Complex Credit Union Leverage Ratio; Risk-Based Capital

Access the Survey:
Members are encouraged to share the survey for completion with staff most appropriate to respond. The on-line survey is hosted by the Association may be found at:

Please complete the survey at your earliest convenience. At this time, the survey will remain open through October 8, 2021.