SW&M Comments on the NCUA’s Risk Based Capital Rule

On May 28, 2014, our office responded to the NCUA’s request for comments concerning its Proposed Rule on Risk Based Capital. Our comments can be found here, or on the NCUA’s website here.  Our comments are provided from the perspective of attorneys representing more than 350 federal and state chartered credit unions nationwide.  From this perspective, we are privy to trends in examination and enforcement and the private concerns of numerous credit unions.

SW&M commented in two major areas regarding the effects of the Proposed Rule and the interaction of the Proposed Rule with other areas of credit union operations: (1) the need for consistency in application of expanded powers for examiners, and limitations on those powers; and (2) the relationship between the Proposed Rule and limitations on and reporting of CUSO investments, particularly the methods by which investments in CUSOs can be reduced or eliminated.

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