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Why every credit union leader should submit a comment letter on the proposed risk-based rule.

By Randy Karnes | Updated on April 24, 2015

The second sentence of CU Times Executive Editor Heather Anderson’s column in the April 15, 2015 issue of CU Times (“Oh, the Irony: The NCUA, NCUSIF & Alabama One”) should be enough to frighten every credit union leader into submitting a comment letter on the proposed risk-based rule – before the April 27 deadline. She mentions NCUA’s intent to push for an expanded NCUSIF … with a risk-based premium structure. One more sign that the agency is out of touch.

A quick read of NCUA’s 2014 audit of the share insurance fund should convince anyone who hasn’t submitted a comment letter on round two of the proposed risk-based capital rule to do so…now! RBC2 assumes that the agency is capable of managing uncertainties, identifying risk and recording potential deficits. But a review of the NCUSIF audit should give pause about that assumption.

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