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BILL HAMPEL
INTERIM PRESIDENT & CEO
MARY DUNN
CUNA DEPUTY GENERAL COUNSEL
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27 Days and Counting
Posted May 02, 2014 by CUNA Regulatory Advocacy
NCUA’s comment deadline to submit RBC comments to the agency is rapidly approaching.  We have formally asked twice for an extension of the comment  period – which we think is a reasonable request given the magnitude of the proposal -- but  have been denied twice.  The deadline for comments to the agency remains May 28.  

Why no extension for one of NCUA’s most important most complex and important rules in a generation?  NCUA says they’ve already been generous: the comment period is 90 days, instead of the usual 60.  


But the agency could provide more time for comments.  NCUA has taken over a year to draft the RBC proposed rule.  Credit unions are asked to fully digest a 198-page proposed rule, consider how it affects their operations, highlight problem areas as they apply to their balance sheets and suggest viable alternatives in a just a few weeks, all while running their credit unions.   

For a proposal this significant, this complicated, and when no one argues time is of the essence, we think a few more weeks is not unreasonable, just as banks got when the federal banking regulators considered Basel.

We at CUNA are tasked with commenting on all aspects of the proposal but your credit does not have to; your letter can be simple.  Whether you use our letter writing tool or submit directly to NCUA at regcomments@ncua.gov, there is no comment more powerful than one that reflects your own concerns.  You can take a single issue, explain why it harms or helps credit unions, and give NCUA an alternative (including doing nothing).  Your credit union can also submit more than one comment letter if you think of something else before the May 28 deadline.   Please don’t forget to send a copy to your Members of Congress, CUNA, and your league.

The proposal is too important to ignore, and the clock is ticking.  Credit unions: it’s time to start writing.

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