|Agency||National Credit Union Administration|
|Rule Name||Prompt Corrective Action - Risk-Based Capital|
|Comment Due Date||04/30/14|
The National Credit Union Administration Board (NCUA) is proposing to amend part 702 of its regulations regarding prompt corrective action (PCA) to restructure the part and make various revisions, including replacing the agency’s current risk-based net worth requirements with new risk-based capital requirements for federally insured “natural person” credit unions.
The following Executive Summary is provided by the Credit Union National Association (CUNA). For CUNA's full, detailed summary, please see the attached CUNA Regulatory Comment Call. CUNA plans to refresh and update their Comment Call as CUNA, the Leagues, and credit unions continue to digest the proposal and identify any additional concerns. This information is dated January 30, 2014.
What NCUA Is Proposing – An Overview
The NCUA is seeking comments for 90 days on a proposal regarding risk based capital (RBC) requirements under its prompt corrective action rules. The proposal would:
NCUA has produced a calculator to help credit unions demine how the proposal would affect their net worth, as the bank regulators provided under their Basel III proposal.
CUNA’s Initial Concerns
We will be updating this document as we continue our review of the 198-page proposal. Initial concerns include the following:
CUNA’s Plan to Address the Rule’s Deficiencies
CUNA is analyzing all aspects of the proposal, including the agency’s legal authority for the proposal and how it compares with Basel III for community banks.
CUNA staff will be working with our Examination and Supervision Subcommittee and others, such as the CUNA Accounting Subcommittee and the CUNA Councils, to develop our official response in our comment letter. We will be meeting with NCUA Board members and staff as well as reaching out to the credit union system to solicit the views of credit unions and leagues. We will also be talking with outside consultants that have particular expertise on Basel III and discussing aspects of the proposal with bank regulators.
For more information about this rulemaking, contact CUNA SVP, Chief Economist Bill Hampel at firstname.lastname@example.org, SVP, Deputy General Counsel Mary Dunn at email@example.com, or Assistant General Counsel Lance Noggle at firstname.lastname@example.org.
Comments Are Urged
CUNA and the Leagues urge credit unions to review the proposal in light of its impact on their operations and to share their views regarding the proposal with CUNA and the Leagues as soon as possible; comment letters to NCUA are also urged, with a copy to CUNA and your credit union’s League. This is a critical proposal and as many credit unions as possible should weigh in with their assessments and concerns.
The proposal has not yet been published in the Federal Register, so a specific comment due date has not been set yet; we will update PowerComment and revise CUNA’s Comment Call document to include the date when it appears in the Federal Register.