It was a really big deal when the National Credit Union Administration found itself flooded with 2,056 comment letters on the agency’s first risk-based capital (RBC1) proposal – it was a new record.
That record was broken in short order when another 2,167 were filed on RBC2.
And it was a really, really big deal when the field of membership update garnered nearly 12,000 letters, easily outpacing RBC1 and 2 combined.
So I can’t be blamed for being a little blasé about the fewer than 1,000 letters filed on NCUA’s Notice of Proposed Rulemaking (NPR) on alternative capital — many of them form letters from banks vehemently opposed to any sort of alternative capital for credit unions. Sure, an NPR doesn’t carry the same level of urgency as an actual proposed rule being on the table. It’s possible, after all, that the regulator will make bankers’ collective day and drop the whole thing entirely.
But then again, isn’t that exactly why more credit unions should have added their two cents?
Back when NCUA had a public briefing on the subject, then-chairman Rick Metsger noted that many credit unions probably didn’t even have much appetite for alternative capital because many are already well capitalized.
Moreover, Metsger added, creating some sort of alternative capital potentially raises “the fundamental question of what it means to be a credit union”—practically handing to banks on a silver platter an argument against any such measure.
Those who didn’t file comments have missed out on an opportunity to proactively shape a proposed rule before it is even proposed. Some might suggest it’s no big deal: they’ll have a second bite at the apple when the agency eventually puts forward an actual proposal…assuming that it does, that is.
