Removing Barriers Blog

CUNA Supports Proposed Increase to “Complex” Credit Union Definition
Posted March 23, 2021 by CUNA Advocacy

Today, CUNA filed a comment letter in support of the NCUA’s proposal to raise the asset threshold for defining a credit union as “complex” for purposes of being subject to any risk-based net worth (RBNW) requirement. The proposed rule would amend the NCUA’s regulations to provide that any RBNW requirement will apply only to a credit union with assets that exceed $500 million and a RBNW requirement that exceeds 6%; this is an increase from the current threshold of $50 million.

We support this proposed rule, as we agree with the NCUA that implementing this regulatory change in advance of the risk-based capital (RBC) rule’s January 1, 2022, effective date will provide capital relief to a significant number of credit unions without substantially decreasing the safety and soundness of credit unions or the NCUSIF.

We applaud the NCUA for its creative and proactive approach over the past year in pursuing regulatory relief aimed at helping credit unions help their members. We believe increasing the complex threshold under the proposal is another step in the right direction.