The NCUA has been announcing for months that the agency is going to change rules relative to risk-based capital for credit unions. The agency intends to have some credit unions who engage in activities that the agency deems risky to hold more capital. Capital is safe. Capital is the regulators' cure-all to "risk."

Capital is the easy way out. Since NCUA first announced it was looking at capital rules, NAFCU has pushed back every step of the way. We have asked the agency to show us why new capital rules are necessary. We asked to be included in the discussions prior to any rulemaking. Yet the agency plodded forward with its "look" at capital rules, keeping everyone in the dark as to what exactly it would propose.

Credit unions are already well-capitalized as an industry. Capital is at an average 10%. The statutory minimum capital level for a well-capitalized credit union is only 7%. If you look at credit union failures going back as far as 10 years, the story is the same, both pre-financial crisis and post-financial crisis.