For many years, NASCUS was one of few voices supporting supplemental capital. Today, we've been joined by many in the credit union system who are eager for other means of raising capital in addition to retained earnings.

Credit union access to other forms of capital is an essential part of credit unions' long term viability. NASCUS also sees capital reform as a safety and soundness issue. However, there are some in the system who are still unconvinced that supplemental capital is a good idea or argue that it contradicts the credit union mission from a philosophical perspective. These and other concerns are overstated and can be addressed.

Recently, NASCUS and some state regulators participated in the International Credit Union Regulators Roundtable where attendees addressed capital for credit unions. We asked the international regulators whether their credit unions would be better off with or without supplemental capital. They unanimously agreed that the credit unions are better positioned with supplemental capital. Further, as discussion among international credit union regulators focused on conforming to BASEL III, it was clear that the U.S. credit union capital structure was far behind our international counterparts and must be reformed soon to keep up with the expectation that capital standards will continue to evolve.