Larry Fazio’s commentary (“Revised RBC Proposal Reflects Lessons Learned,” Jan. 22, 2015, CU Times) cites the financial crisis as the catalyst for the NCUA’s second risk-based capital proposal, stating that many of the failures would have been prevented in part if this new rule had been in place.

Unfortunately, this is an overgeneralization of a complex issue; capital is only part of the equation. In fact, credit unions experienced many fewer failures than their banking brethren during the crisis, and banks were operating under a risk-based system similar to what NCUA had proposed at that time.

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