RBC Comment Letters: 2,027 and Counting
The NCUA said on Tuesday it received 2,027 comment letters on the risk-based capital proposal, which were submitted prior to the May 28 deadline.
However, NCUA Public Affairs Specialist John Fairbanks said the latest figure is the total number of individual letters, not the number of stakeholders that filed letters. Some credit unions and industry organizations filed several letters.
Two credit unions and two CUSOs topped the list of the most comment letters filed.
The $394 million Resource One Credit Union in Dallas submitted 45 comment letters to the agency on the proposed risk-based capital rule.
“Although the regulation has good intentions, the one-size-fits-all approach applies to categories of assets, is a major weakness. Credit unions are diverse and there should be a standardization with the proposal,” wrote Resource One CEO Jim Brisendine in his comment letter.
The $306 million Frankenmuth Credit Union in Frankenmuth, Mich., filed 52 letters. Many of them were variations on the same template.
“My understanding is that this proposal will affect both my credit union and the CUSOs in which we participate in a very negative way,” wrote loan underwriter Angela Engelhardt.
“It seems that most industry professionals view this proposal as going well beyond what is necessary to protect the insurance fund, and with the resulting consequence of limiting services to members,” the letter also said.
Xtend, Inc., a CUSO based in Grand Rapids, Mich., submitted 47 letters, and CU*Answers, a CUSO also headquartered in Grand Rapids, filed 129.
“The proposed changes to the risk-based capital requirements for credit unions is going far beyond what is necessary to protect the insurance fund and in the end will negatively impact services to the credit union members,” said CU*Answers CIO Jody Karnes. “It will also discourage credit unions from investing in CUSOs such as the one I work for.”
Aside from Karnes’ letter, many other letters from CU*Answers repeated the same format.
“The proposed regulation seriously defeats the cooperative principles we were founded upon; the same core principles upon which the entire credit union industry was formed,” wrote Programmer Analyst Alida Braafhart.
“Every letter received will be read by an agency staff member,” Fairbanks said.
He added the NCUA is still in the process of counting the comment letters that have been filed.