The second sentenceof Heather Anderson's column in the April 15 issue of CreditUnion Times (“Oh, the Irony: The NCUA, NCUSIF & Alabama One”) should beenough to frighten every credit union leader into submitting acomment letter on the proposed risk-based rule – beforethe April 27 deadline. You mention NCUA's intent to push for anexpanded NCUSIF … with a risk-based premium structure. One moresign that the agency is out of touch.

A quick read of NCUA's 2014 audit of the share insurance fundshould convince anyone who hasn't submitted a comment letter onround two of the proposed risk-based capital rule to do so …now! RBC II assumes that the Agency is capable ofmanaging uncertainties, identifying risk and recording potentialdeficits. But a review of the NCUSIF audit should give pause aboutthat assumption.

In managing the NCUSIF, the NCUA is really managing themember-owners' fund – a combined capital source for every creditunion in the nation. Yet, the Agency offers no commentary on whyits accounting numbers bear no resemblance to real events. In fact,the results make clear that NCUA dramatically understated theFund's bottom line during the financial crisis, and overstated itin the years afterward. Just as alarming, the funding from thepremium assessments is running out, yet the Agency isn't close tobreak-even on a current period versus actual events.