The letter was in response to an Oct. 6 letter from the three congressmen to Matz urging her to voluntarily comply with requirements of the bill before finalizing RBC2. The three voiced concerns in that letter that RBC2 would hamper credit union lending. The bill, referred to as stop and study, passed the House Financial Services Committee Sept. 30 by a convincing 50-9 vote.

If the bill became law, it would require the NCUA to study and report to Congress an analysis of the NCUA's legal authority to enforce the rule, a comparison of bank and credit union risk weights, the rationale for each risk weight and an overview of how the rule would apply to credit union capital buffers.

Matz told the bill's sponsors the NCUA had already examined those four points and also carefully considered the views of thousands of stakeholders.

Matz reminded the congressmen the Federal Credit Union Act requires the NCUA to provide parity with bank regulations; banking agencies adopted risk-based capital standards in 2013. She also noted that the Government Accountability Office and the NCUA's Inspector General also recommended a risk-based capital rule.

“To address congressional concerns about the first proposed rule, we narrowed the scope of the revised proposed rule,” Matz wrote in the letter. “In all, the revised risk-based capital rule would apply to just 22% of credit unions, those with asset exceeding $100 million. We also further calibrated the risk weights so that 78.1% of complex credit union assets would have equivalent risk weights to banks and thrifts, and we assigned 18.6% of assets of complex credit unions a lower risk weight than banks and thrifts.”

The Oct. 15 board meeting, which is scheduled to begin at 10 a.m. Eastern Time, will likely be a contentious one, as Board Member Mark McWatters pledged to vote against the final risk-based capital rule. McWatters said the NCUA does not have legal authority to require a two-tiered risk-based capital system.

The open board meeting agenda also included a community charter request, a proposed rule on bank note investments and the quarterly report of the NCUSIF.

A closed board meeting, scheduled to occur after the open meeting, will address consideration of a supervisory action, a review of a supervisory action and a personnel matter.

NCUA board meeting can be viewed online via livestream. The NCUA provides a link on the mainpage of its website shortly before each meeting begins.