We respectfully disagree with the assertion made here ("RBC Legal Challene Is a Waste," Jan. 28, 2015, Credit Union Times) about whether it's worthwhile for credit union industry resources to be used finding a "legal way out of risk-based capital." No one's trying to prevent risk-based capital, but we are working diligently to make sure a capital system for credit unions is structured and implemented in a way that makes sense. We want a comprehensive approach to credit union capital requirements, and to get that we need Congress to act.

We address this elsewhere in your publication in an editorial from Carrie Hunt, our senior vice president of government affairs and general counsel ("More Cost, Little Benefit," Jan. 26, 2015, CU Times). The two-tier RBC ratio we're all talking about now doesn't just raise legal questions – though it does raise them – it poses a very real cost concern for healthy credit unions. We've crunched the numbers, and we have found that the two-tier ratio today would cost credit unions nearly half a billion dollars more than a one-tier system. That's more than pocket change.

The two-tier ratio isn't the only problem with this proposed rule. This isn't a complete approach to capital but is just another piece of it; credit unions would be better off with one rule that addressed the entire capital issue than numerous parts, which do more than they should to increase compliance burdens. We still see no solution from NCUA on supplemental capital for all credit unions; that has to come from Congress. And we don't know how credit unions will fare under this proposed rule and the interest-rate risk proposal the agency has promised to draft but has yet to reveal.

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