CUNA and NAFCU say the NCUA's proposed stress test rule forcredit unions over $10 billion in assets is costly and unnecessaryconsidering the four largest credit unions in the nation alreadyconduct their own tests.

The credit unions affected would be the $54 billion Navy FederalCredit Union in Vienna, Va., the $27 billion State Employees'Credit Union of Raleigh, N.C., the $16 billion Pentagon FederalCredit Union in Alexandria, Va., and the $12 billion BECU inTukwila, Wash. The NCUA's stress tests would be based on Sept. 30financial data.

Under the rule, these credit unions would be required tomaintain a stress test capital ratio of at least 5% – higher thanthe 4% minimum leverage ratio required of banks since credit unionsare unable to raise capital in the form of stockholder equity.

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