Removing Barriers Blog

Comment Letter Filed with NCUA on Subordinated Debt Proposal
Posted July 02, 2020 by dyi

CUNA filed a letter today in support of the NCUA’s proposed rule on subordinated debt. The proposal would allow LICUs, complex credit unions, and new credit unions to issue subordinated debt. The letter focuses on the NCUA’s legal authority to issue such a rule (since we anticipate this is an area where banks may attack the proposal). CUNA also provides suggestions on how the proposal can be improved, including in the area of required disclosure documents.