Press

The Honorable Debbie Matz
Chairman
National Credit Union Administration Board 1775 Duke Street
Alexandria, VA 22314

Dear Chairman Matz:

The Credit Union National Association is very pleased by your announcement today that NCUA will hold listening sessions in San Francisco, Chicago, and Washington, DC in June and July. As you know, we wrote to you on February 14, 2014 requesting a hearing on the risk based capital proposal. While any NCUA initiative could be raised by credit unions attending the sessions, the meetings will certainly provide a very important opportunity for credit unions to express their views on the proposal directly to the agency and to hear the responses of their peers.

In that connection, even though the listening sessions may be after the end of the comment period, we urge the Board to consider all comments made at the sessions on the risk based capital (RBC) proposal as part of the official administrative record.

This approach is permissible under the Administrative Procedure Act. Moreover, this approach will ensure that information and comments provided at the sessions are given full consideration by NCUA, thereby supplementing information obtained through comment letters. In addition, it will allow the agency to develop a more complete record to support its decisions regarding how to proceed with the proposal and the inclusion of revisions. Given the significance of this proposal, we feel having the most complete administrative record possible is essential.

Many concerns have already been raised about the proposal and as we have indicated, CUNA’s Governmental Affairs Conference will be a focal point for credit unions to learn more about the proposed rule and its implications for their operations.

However, there is no substitute for a dialogue with NCUA on the proposal. Given the fact that the listening sessions will be held after credit unions have had time to analyze the proposal’s impact more thoroughly, we urge the agency to assure the credit union system that comments at the sessions will be part of the administrative record.

We believe the agency, credit unions, and the rulemaking process will benefit from this approach and that all parties will have additional incentives to be prepared with facts and data to support their views.

Thank you for your further attention to this request. We are looking forward to seeing you Monday at the CUNA GAC.