Read your take on why a RBC legal challenge is a waste. (“RBC Legal Challenge Is a Waste,” Jan. 28, 2015, Credit Union Times) Honestly surprised to hear you think that CUNA and NAFCU would be wasting time and effort as well as a considerable amount of cash on fighting something that harms credit unions and in the vernacular of the street is a ”lot of crap”. Most commentators have already noted that this is stupid and unnecessary but putting this aside for the moment your assertion begs the question. Just what do you think CUNA, NAFCU and the other groups should do? Should they roll over and play dead? Perhaps they should just ignore the whole thing and wait for the next threat to ignore as well. Are you kidding me?

Challenging NCUA on this issue is not only right it is an imperative for the Trades. Failure to represent the credit unions they serve would just be another silent yet defining statement of their unwillingness to fight for the credit unions they represent no matter what the cost.

You seem puzzled that credit unions have not been swept up in the Basel standards before this. Don't be. Basel's targets have never been the small institutions like credit unions and community banks but rather the large multinational banks that really can affect the world economies with their manipulations and self-serving strategies. They seem impervious to the edicts of not one not two but three Basel accords.

Basel is reactive something bad happens and they meet to head off more occurrences generally with stricter capital standards. NCUA, on the other hand, is proactive heading off the IRR's of the world even if there is no evidence of such. Can you spell deflation? Additionally have you looked into what is going on in the 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 severe punishments guaranteed for the bad financial actors of the world they can have as many Basel's as they want and nothing will change. If there were only credit unions and community banks there would be no Basel. This point bears reiteration with NCUA.

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

Dennis Moriarty

CEO

Unity Credit Union

Warren, Mich.