Now is the Critical Moment to File RBC2 Comment Letter

Now is the time to submit your comment letters on RBC2. To learn more about the proposal and resources available to improve our advocacy efforts visit our RBC toolkit.

NCUA’s comment deadline for its second proposed rule for risk-based capital (RBC2) is rapidly approaching, with less than a month left until the April 27 deadline.

Northwest credit unions responded overwhelmingly during the first comment period, which resulted in a substantially improved rule. The Association is urging credit unions to take this opportunity to make their voices heard once more. We encourage credit unions to thank the NCUA board and staff for listening to our concerns, as well as pointing out additional items that still need to be addressed. See the talking points developed by NWCUA’s Regulatory Advisory Committee, on our RBC toolkit, under the “Risk-Based Capital Important Dates” header.

“The revised RBC rule is significantly better than the original version. In our letter we made sure to thank the NCUA for making necessary changes and for listening to our feedback,” said Matt Stephenson, executive vice president and Rogue Credit Union. “Our constructive comments focused on the general need for the proposal, interest rate risk and supplemental capital options.”

See the letter that Stephenson and Rogue filed here.

Tell the NCUA how the proposed risk-based capital rule will impact your credit union by sending a letter before the April 27 deadline.

Comment Letter Writing Tips

  1. You don’t have to write a long comprehensive letter; keep it simple.
  2. Introduce your credit union and your members.
  3. Thank the NCUA Board and staff for listening to our concerns.
  4. Share specific stories about how this proposal might impact your credit union.
  5. Explain your policy suggestions and provide your reasoning; even if you generally agree with a proposed rule, it can always be improved.

The next 27 days are critical as the official comment period ends April 27. Please respond. To learn more about the proposal and resources available to improve our advocacy efforts visit our RBC toolkit.

Other resources you might find useful are the comments of other credit unions and CUNA’s PowerComment tool.

Please continue to share the resources you are developing to support this campaign and look for additional support and resources to be added to the toolkit.

If you have any questions or would like to share your thoughts and concerns please email John Trull at or call him at 503.350.2209.


Posted in Advocacy News, NCUA.