With the recent unveiling of the revised proposal for Risk Based Capital, the NCUA has opened up the rule to comments from the public. CU*Answers CEO Randy Karnes is calling on all participants of the CU*Answers and cuasterisk.com networks to submit their comments to the NCUA before the April 27, 2015 deadline. “During the first round of comments, credit unions and industry members let the NCUA know their complaints about the proposed rule; what the NCUA might be counting on is that people have worn themselves out of following the rule and they will get what they want with minor concessions,” said Karnes.

The 100% credit union-owned CUSO CEO continued, “This time might be different. The NCUA Board is split, the debate is more public than ever, and now is the time for opponents of the rule to drive home the message that RBC is damaging to credit unions and to their CUSO investments. Worse yet, the process is still flawed, but we might finally have an advocate for better regulation, better Board transparency, and respect for processes that include credit unions in the negotiations.” To his own staff he warned that the rule discourages CUSO investment and lumps all CUSOs into a single category without any consideration for the work they do and the services they offer, casting a shadow over their futures.

To assist with submitting comments to the NCUA, Karnes and CU*Answers have created a comment engine to facilitate the process. Credit union staff, boards, members, and industry professionals are encouraged to visit the site, learn more about RBC2, and to submit their own comment. Karnes concluded, “This is not a request for a blind sign of support of our opinions in this effort; this is a call to all involved to do some research, think the proposal through, and to respond. I hope visitors to the site will find it compelling and encourage the type of response this rule needs.”