Risk-Based Net Worth
Comment Letter Workshop

May 19, 2014

America's Credit Union Museum
418 Notre Dame Ave
Manchester, NH 

The National Credit Union Administration Board's proposal to impose risk-based capital requirements on federally-insured credit unions is the most important regulatory proposal facing the industry today.  The comment period for the proposed rule ends May 28, 2014.

While the concept of risk-based net worth could be beneficial, the proposed rule will have significant negative effects on credit unions if it is implemented in its current form. League and Association President Paul Gentile notes that “the reaction amongst credit unions to NCUA's proposed risk-based capital rule is that growth will falter under the new standards and that not enough has been done to reward effective risk management performance.  As a result, the League is committed to helping our members meet the challenges of the proposed rule starting by effective advocacy through the comment letter process.”

Given the heightened level of concern that this proposal presents for even credit unions with assets below the proposal's direct coverage trigger of over $50 million in assets, the League is a resource to your credit union to underscore to NCUA the need for substantive change.  Strength is in the number of comment letters presented to the Agency to secure positive changes.  Not form letters, but letters highlighting its real impact and real concerns.
The League has made available a host of resources on its website, including a member survey, and will be submitting a robust comment letter to the NCUA.  In encouraging credit unions to do the same, this workshop is available to members at no cost as another tool to help dispel the myths of drafting a comment letter and to provide the necessary elements to craft such a letter with impact specific to your credit union.
Key points to be considered at the forum include:

        Why is NCUA going forward with this proposal now?

        What is the real threat to your credit union?

        Should NCUA be able to require credit unions to hold more regular     capital than the current statutory level?

        Why are the risk weighting so different than banks?

        Why does the proposal not include credit risk or consider     the complete balance sheet of the credit union?

        How will my comment letter make an impact?

These important issues and more will be discussed. This workshop will permit you to share your views on this proposal in an informal setting with your peers.
League staff will lead the discussion and a customized comment letter for your credit union will be developed.  This is a working meeting we encourage you to take advantage of as part of your membership in the League. 

TIME: 9:30 a.m. to  11:30 a.m. 

FEE: There is NO cost for this workshop