Michael E. FryzelThe recent action by the NCUA Board to issue a revised risk-based capital rule for a 90-day comment period has created a new and unique opportunity for the two national credit union trade associations to shift the battleground from Alexandria, Va., to the nation’s capital.

Aside from the legal issue of whether or not the NCUA has the authority to issue a two-tiered RBC rule, there remains in the minds of many key changes that should be made in order for the rule to be palatable.

Improvements in RBC 2 have been noted but concerns still linger regarding the definition of complex credit union, risk weights, capital to be raised, number of credit unions impacted and actual cost to the industry to implement the rule.

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