Mathematical and chemical equations must balance if they're going to achieve their desired outcomes, and the same holds true for the NCUA's revised risk-based capital rule, which seems designed to stabilize balance sheets at the expense of member benefits, according to Dennis Dollar, a principal partner with Dollar Associates LLC in Birmingham, Ala. and former NCUA chairman.

"The concept of risk-based capital is, within itself, solid regulatory thinking as lower-risk balance sheets should require less capital retention than higher-risk balance sheets, but the details are difficult to achieve with balance," Dollar said. "The NCUA has definitely made improvements in each version of RBC, and they are obviously listening to their stakeholders as they should."

The question many of the 2,167 letter-writers have asked about RBC2, and to which the NCUA has yet to thoughtfully respond, is when the attendance to risk outweighs the opportunity to serve members. The amount of increased capital that RBC2 requires to be pledged to the regulator will for some institutions reduce the funds that can be used to provide products and services, and essentially hamstring the credit union's ability to invest in meaningful growth, Dollar said.