Keesee Urges Nation’s Small Credit Unions to Comment on Risk-Based Capital Proposal

NWCUA Board Chair Debie Keesee is urging the nation’s small credit unions to add their voices to the debate over the NCUA’s Risk-Based Capital proposal, saying that “if adopted as proposed, it will have significant negative impact on the movement, including small credit unions like yours.”

“In the absence of more comprehensive reform (including lower leverage ratios and access to alternative capital), we do not support the proposal and think it should be withdrawn,” Keesee says in a letter emailed to credit union executives last week.

Keesee, president and CEO of Spokane Media Federal Credit Union, wrote the letter on behalf of CUNA’s Small Credit Union Committee, which she chairs. On Friday, CUNA President/CEO Bill Cheney said it was being sent to credit unions across the country as part of the association’s effort to generate 1,000 comment letters to the NCUA by its May 28 deadline.

Through Friday, more than 450 comment letters had been submitted, Cheney said — “one of the largest totals on record for comments to the agency on any subject, by our estimate.”

In her letter, Keesee implores her colleagues to help drive that number higher.

While her committee supports the idea of risk-based capital, Keesee writes, it does not believe in a one-size-fits-all regulation that would force credit unions to “pay for the sins of those who take on too much risk.” She calls the NCUA proposal an “excessively blunt instrument” that could result in lower levels of member service and satisfaction and put credit unions at a competitive disadvantage in the financial marketplace.

“Policy makers should be encouraging more of what credit unions do, not less.” Keesee says. “This proposal demands less.”

Keesee spells out the committee’s specific objections to the Risk-Based Capital proposal and the improvements it believes small credit unions should suggest in their comment letters, which must be submitted to the NCUA by Wednesday, May 28.

You can read the full text of Keesee’s letter here.

To make the comment process easier, the NWCUA has created a resource-rich Web page that includes key talking points and a draft letter that credit unions can use as a starting point to craft their own messages. The page also includes links to the NCUA’s Risk-Based Capital calculator and to CUNA’s RBC Action Center, which contains more information and tools.

Many Northwest credit unions have already submitted their comments, and some of those letters are included on the NWCUA’s webpage.

Questions about this story? Contact Gary M. Stein: 503.350.2216,

Posted in Advocacy News, CUNA, Federal, NWCUA.