Comment Letter to NCUA


The Federation added its voice to the dialogue within the credit union movement on proposed risk based capital rules.  While acknowledging benefits to a risk capital structure, the Federation echoed concerns expressed by many in the movement about the particular categories and risk weightings in current proposed rules.  The proposed threshold for complex credit unions is too low, threatening to hamper one of our fastest growing credit union segments – credit unions with assets between $50 million – $250 million.   Moreover, the Federation pointed to key areas in which the proposed rules could result in restricting critical credit union lending activities to low- and moderate income individuals and communities.

Download the letter.

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