Last week, by a bipartisan margin of 50-9, the HouseFinancial Services Committee sent an undeniable message to theNCUA: Take more time to review the law, assess the need foradditional regulation, evaluate alternatives and consider the realimpact now and into the future before moving ahead with theRisk-Based Capital 2 final rule.

This is a message I welcomed and championed in my writtendissent (available on the agency’s website) to the issuance by theagency of its proposed RBC2 rule last January as contrary to aplain reading of the Federal Credit Union Act.

I think the agency would do well to heed this message for othermajor regulatory issues as well, most notably how the agency dealswith the growing regulatory burden confronting credit unions,particularly small credit unions. The increasing number, scope andcosts associated with regulatory requirements, not just from theNCUA but from all agencies, that credit unions must manage is aconcern that the NCUA must take more seriously and devote moreresources toward addressing in a meaningful way.

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