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.