The votes have been cast and results are being tallied, and so far, one thing is clear: Based on early returns, credit unions appear to dislike the NCUA's revision of its proposed risk-based capital rule just as much as or even more so than the original version.

As of its deadline of midnight on April 27, the NCUA had received 2,167 letters and emails, most of which expressed opinions of mild concern to downright disgust at RBC2, as the rule is called. This record number of contacts compares unfavorably to the 2,056 letters and emails the agency received last year in response to RBC1, which until RBC2′s release last week was the record number of comments regulators had received about any single proposal.

Concerns over the rule's implementation, its criteria and standards, and even the agency's legal authority to enact a proposal that changes the NCUA's regulatory structure to a two-tiered system filled thousands of pages of commentary from credit unions, trade associations, consultants and credit union members.