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Share your comments on risk-based capital proposal


The National Credit Union Administration (NCUA) issued a proposed rule on risk based net worth requirements that would affect all federally insured credit unions—including state chartered credit unions—with over $50 million in assets. The proposal includes risk-weighting of certain assets (e.g., real estate and member business loans) and would allow NCUA to raise the risk-based capital requirement of an individual credit union above the normal threshold levels based on subjective factors.


Under the proposal, previously well-capitalized or adequately capitalized credit unions could fall out of those ranges. Use CUNA’s simulator (login required) to determine how changes in your asset composition affect the risk-based capital ratio, analyze the types of changes in asset composition required to raise the risk-based capital ratio to an acceptable level, study the implications of planned changes to your balance sheet and acquire a clearer understanding of the proposal's effects before weighing in.

Did you know?

Each year, the NCUA reviews one-third of its regulations and encourages credit unions to provide input on improvements.


In 2014, the agency will review, in part:


  • Records preservation
  • Loans in flood hazard areas
  • Bank Secrecy Act compliance
  • Tort claims against the government


Read the complete list.

Read CUNA's Comment Call and share your comments by:


  • Contacting Jo Whiting or Paul Guttormsson at The League by May 21 (deadline extended!). We will prepare a comment response on behalf of Wisconsin credit unions; or



The Credit Union National Association offers a template letter you can customize in its RBC Resource Center (login required). The Leauge will also have kiosks at Convention offering a starter-letter you can customize and Legal Affairs staff available to assist.


Because Members of Congress play a role in regulatory oversight, it is also helpful to copy your Congressional representative on your correspondence.


The League will be urging the NCUA to consider whether the rule is needed at all, given how well most credit unions came through the recent recession, or how to narrow the rule to minimize unintended consequences.


The League advocates for Wisconsin credit unions on regulatory issues to ensure their voice is well represented on issues affecting the service that Wisconsin's 2.4 million members recieve.


Credit unions are represented in the regulatory advocacy process by The League's Regulatory Advocacy Council.


©2005 Wisconsin Credit Union League. All rights reserved.
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