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.

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