Does everyone feel they had their say regarding the NCUA's proposed rules for corporate credit unions? If you didn't join your several hundred colleagues in writing in, then you are no longer allowed to complain. The NCUA allowed for open discussion in its town halls and the comment process was open to anyone. This is where the agency has been transparent.

The thrust of the corporate proposal is the capital ratios it would require for corporate credit unions to be adequately capitalized a 4% leverage ratio, a Tier 1 risk-based capital ratio of 4% and total risk-based capital ratio of 8%. This part of the proposal mirrors Basel and that is good and logical. Hopefully, a similar risk-based capital system can be applied to natural person credit unions one day in the near term.

However, achieving these in a one-year time frame would be Herculean, if not impossible by most accounts. While the NCUA has said it could be flexible with the one-year time frame if a corporate was heading in the right direction, the near impossibility of these requirements-as consistently pointed out in the comment letters and at the town halls-calls into question the NCUA's credibility. The proposal leads to one of two conclusions: Either the NCUA is out of touch with how the institutions they regulate run, or the NCUA is looking to shut down nearly all, if not all, the corporates.