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Wisconsin credit unions voiced their concerns on Risk-Based Capital proposal



Wisconsin credit unions shared their perspectives on the potential harm that could come from the National Credit Union Administration's Risk-Based Capital Proposal by filing comment letters with the agency in May.


While some of those letters are still being processed and not reflected in the total, your League and already more than 40 Wisconsin credit unions—and others—have submitted their thoughts in upwards of 50 letters. CUNA filed a 47-page letter reflecting comments from credit unions nationwide.


Our multi-pronged strategy to see the proposal improved may already be paying off, largely due to the strong grassroots response. More than 2,052 comment letters have been submitted from credit unions and others nationwide.


Thank you to these Wisconsin credit unions (and others) who wrote letters to NCUA to voice their concerns:


ImageWI Senator Baldwin joins 2,000+ voices commenting on RBC proposal



Wisconsin Senator Tammy Baldwin sent a letter to the NCUA urging changes to improve its Risk-Based Capital proposal. See all the Congressional letters to NCUA.


75% of Representatives in the U.S. House co-signed a letter also advocating for changes. It included Wisconsin Reps:


  • Sean Duffy (R-Weston)
  • Ron Kind (D-La Crosse)
  • Reid Ribble (R-Sherwood)
  • Gwen Moore (D-Milwaukee)
  • Mark Pocan (D-Madison)
  • Jim Sensenbrenner (R-Menomonee Falls)


Other Wisconsin entities weighing in include:



Concerns have also been filed by:


  • Altra Federal
  • Avestar
  • Badger-Globe
  • Brewery
  • Brokaw
  • Central City
  • CitizensFirst
  • Community
  • Connexus
  • County-City
  • CoVantage
  • Dane County
  • Empower
  • Enterprise
  • Evergreen
  • Fond du Lac
  • Glacier Hills
  • Guardian (also Steve Wesson)
  • Hayward Community
  • Heartland
  • Kohler
  • Landmark
  • Marathon Co. Empls.
  • Marshfield Medical
  • Members First
  • N.E.W.
  • Northwestern Mutual
  • Oakdale
  • Post Office
  • Premier Financial
  • Prime Financial
  • Prospera
  • RiverWood-Maritime
  • Royal
  • Taylor
  • Thrivent Federal
  • United One
  • WEA
  • WESTconsin
  • Westby Co-op 
  • Winnebago Community
  • Wisconsin Latvian


Credit unions also have another opportunity to influence improvements to the proposal by attending a July 10 NCUA listening session in Chicago. Registrations for that session have already reached capacity.


The proposal, as written, could cut credit union capital buffers by billions of dollars, with $200 million in lost capital affecting Wisconsin. It has thus been called a "ground zero" issue for credit unions.

©2005 Wisconsin Credit Union League. All rights reserved.
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