CCUA Survey Seeks Your Comments on NCUA’s RBC Proposal

The National Credit Union Administration (“NCUA”) recently issued an advance notice of proposed rulemaking (“ANPR”) regarding potential simplified alternatives to NCUA’s Risk-Based Capital (“RBC”) rule. The RBC rule is scheduled to replace the RBNW rule beginning on January 1, 2022, and is conceptually similar to the Federal Deposit Insurance Corporation’s (“FDIC”) Community Bank Leverage Ratio. The Cooperative Credit Union Association (“Association”) views this request for comments as positive and significant in leading to increased regulatory clarity; therefore, a robust comment letter reflecting your views in planned.

The ANPR on a simplified RBC approach seeks comments regarding two potential simplified compliance alternatives to its Basel-Framework-based RBC rule: (a) the “Risk-based Leverage Ratio” (“RBLR”), which would replace the RBC rule; or (b) the “Complex Credit Union Leverage Ratio” (“CCULR”), which would be an optional alternative to the RBC rule that complex FICUs could opt into. These two potential alternatives are based on the Net Worth Ratio and are mutually exclusive; if NCUA proceeds to the next step and releases a proposed rule on this issue, then it would choose to move forward with either the RBLR or the CCULR. 

The Association’s survey seeking your views on the Risk Based Capital proposal is available HERE. Please respond no later than Thursday, May 6th, 2021.  

The full NCUA Advanced Notice of Proposed Rulemaking on simplified alternatives to the RBC rule is available HERE.

Thank you in advance for your efforts to provide your views on this important issue for your credit union and for all Association members.