Read your take on why a RBC legal challenge is a waste. (“RBCLegal Challenge Is a Waste,” Jan. 28, 2015, Credit UnionTimes) Honestly surprised to hear you think that CUNA andNAFCU would be wasting time and effort as well as a considerableamount of cash on fighting something that harms credit unions andin the vernacular of the street is a ”lot of crap”. Mostcommentators have already noted that this is stupid and unnecessarybut putting this aside for the moment your assertion begs thequestion. Just what do you think CUNA, NAFCU and the other groupsshould do? Should they roll over and play dead? Perhaps they shouldjust ignore the whole thing and wait for the next threat to ignoreas well. Are you kidding me?

Challenging NCUA on this issue is not only right it is animperative for the Trades. Failure to represent the credit unionsthey serve would just be another silent yet defining statement oftheir unwillingness to fight for the credit unions they representno matter what the cost.

You seem puzzled that credit unions have not been swept up inthe Basel standards before this. Don't be. Basel's targets havenever been the small institutions like credit unions and communitybanks but rather the large multinational banks that really canaffect the world economies with their manipulations andself-serving strategies. They seem impervious to the edicts of notone not two but three Basel accords.

Basel is reactive something bad happens and they meet to headoff more occurrences generally with stricter capital standards.NCUA, on the other hand, is proactive heading off the IRR's of theworld even if there is no evidence of such. Can you spelldeflation? Additionally have you looked into what is going on inthe world despite the new standards?

I think the global mess won't be fixed by adoption of Basel III,iv or whatever. The real truth is that without certain and severepunishments guaranteed for the bad financial actors of the worldthey can have as many Basel's as they want and nothing will change.If there were only credit unions and community banks there would beno Basel. This point bears reiteration with NCUA.

RBC2, written by the same people that gave us RBC1, is onlycapable of harming credit unions and members by forcing capitalstandards that (in the case of credit unions) simply direct moreearnings to reserves with little benefit to members. Realisticallyit also increases pressures to find other sources of revenue (fees)that increase costs, generally to those that can least afford it inthe membership, simply to assuage the Federal Regulator and protectthe “fund”'. In the final analysis continued efforts to imposethese standards have reduced the credit unions ability to competeand will eventually lead to our movement/industry demise. Picture aworld where only the big guys are left. BTO's assertion that you“haven't seen nothing yet” would have us remembering the old dayswith fondness. If you are not mightily unnerved by the fact thatthe architects of RBC2 are the same people that gave us RBC1 I havea bridge for sale.

Dennis Moriarty

CEO

Unity Credit Union

Warren, Mich.