The NCUA removed interest rate risk provisions from its risk-based capital rule after credit unions overwhelmingly voiced their opposition. However, if the Switzerland-based Basel Committee on Banking Supervision includes all institutions in its interest rate risk guidelines, credit unions will likely see a new interest rate rule from the NCUA that could require them to increase capital to offset the risk.

"Since the RBC proposal is based on Basel III, [the NCUA is] probably looking very carefully at this proposal," WOCCU Vice President and General Counsel Michael Edwards said. "It will for sure be implemented for big banks, probably community banks, too."

Edwards said after years of WOCCU advocacy for small institutions, the Basel Committee is starting to more seriously consider exemptions when appropriate. In the interest rate consultative document released in June, the committee said the proposal would be mandatory for large, internationally active banks. However, regulators would have national discretion to apply their interest rate risk framework to non-internationally active institutions.