CUNA President/CEO Bill Cheney wrote lawmakers that the measure “would provide credit unions with appropriate ability to raise capital from sources other than retained earnings without putting in jeopardy the 'one member, one vote' principle that is the bedrock of the credit union ownership structure.''

NAFCU President/CEO Fred Becker wrote lawmakers that allowing supplemental capital would “further minimize the probability of credit union insolvency, ensure they continue to serve the nearly 94 million Americans who rely on credit unions as a vital source of financial services, and allow them to grow to meet the needs of members.''

In the past, CUNA has expressed concern that the NCUA would place too many regulatory constraints on credit unions that want to seek secondary capital. NAFCU expressed concern about letting supplemental capital from outside the credit union system.

In April 2010, a report by an NCUA task force chaired by Board Member Gigi Hyland said any capital must adhere to three principles: preservation of the cooperative credit union model, robust investor safeguards and increased prudential safety and soundness safeguards.

The report noted that the agency's supervisory experience with the 41 low-income credit unions (out of 1,102) that receive secondary capital has been “mixed.” It criticized some of those credit unions for poor due diligence and “premature and excessively ambitious concentrations of uninsured secondary capital to support unproven or poorly performing programs.”