The Nussle Report

CUNA/League System significantly changed final risk-based capital rule:

We can all be proud of the effect the CUNA/League System had on the final risk-based capital rule approved yesterday by the National Credit Union Administration (NCUA). The rule has a Jan. 1, 2019, implementation date. I am grateful that members of CUNA’s Examination and Supervision and Consumer Protection Subcommittees were here for NCUA’s board meeting. They had the first meetings with NCUA following the agency’s decision.

Make no mistake: we believe this rule is still a solution in search of a problem. Since the initial proposal 20 months ago, CUNA, the Leagues, and credit unions have worked together to execute one of the most coordinated and successful advocacy campaigns in the past 15 years to ensure we secured the best possible results. We successfully sought major reductions in a number of the risk weights and the elimination of interest rate risk from the RBC approach. Without our combined advocacy efforts, there is no question that the final rule would have been much worse. I commend the agency’s intention to have a supplemental capital rule in effect by the effective date of this rule to allow supplemental capital for purposes of risk-based capital compliance.

However, I remain disappointed that NCUA retained its additional capital adequacy requirement. You can be sure we’ll be pushing for examiner guidance and training in order to place some boundaries around this wildcard requirement. We’ll also continue to urge the agency to release a study on its rulemaking approach, impact and cost of the rule to lawmakers, stakeholders and credit unions.
This Removing Barriers Blog post takes a look at how our successful CUNA/League advocacy effort brought about significant and meaningful improvements to the proposal. 
My press statement yesterday has more detail on the agency’s action.

NCUA responds to CUNA/League advocacy on FOM:

In other board action yesterday, NCUA approved changes to community credit union charter enhancements. These long-advocated commonsense changes are a good step forward to updating the field-of-membership (FOM) process where appropriate authority for changes are delegated to staff. These changes will remove barriers to various credit union charter updates.

CFPB ignores credit union concerns, moves forward with onerous HMDA rule:

I was very disappointed by the action taken yesterday by the Consumer Financial Protection Bureau (CFPB) when it announced its intention to finalize a new Home Mortgage Disclosure Act (HMDA) rule. The new rule includes home equity lines of credit and a more complex data requirement. While the new rule raises thresholds for mortgages and lines of credit and pares back the number of data requirements from the original proposal, at a time when the bureau should be working to increase the availability of credit to middle-class America, it’s chosen to impose staggering amounts of regulatory burden for credit unions. CUNA has written to the bureau a number of times, and I’ve met with Director Richard Cordray urging the bureau to use its authority to exempt credit unions from HMDA provisions. If the bureau’s intent is to stifle available credit to consumers, it’s succeeding. While Cordray continues to publicly state that credit unions in no way contributed to the financial crisis, it’s clear the bureau continues to ignore that very important point in its rulemaking.

CUNA’s MAP takes credit union awareness to presidential campaigns:

Through CUNA’s Member Activation Program (MAP) we’ve launched a campaign focused on connecting the advantages of credit union membership with the economic needs of the middle class. “Strong Credit Unions, Strong Middle Class” is aimed at capturing the attention of the presidential campaigns regarding the advantages credit unions offer middle-class Americans. Our new website offers consumers the opportunity to tweet the candidates about the benefits of being a credit union member. The goal of this campaign is to further educate our members about the benefits of membership in a credit union and convey that stronger credit unions mean a stronger middle class. For additional information about this program, please contact Richard Gose or Adam Engelman.

Education mission to Cuba opens doors, highlights ICU Day and the credit union advantage:

During the week we celebrated International Credit Union Day, Karen and I participated in a credit union education mission to Cuba. The trip brought the first fully credit union-focused group to Havana since the U.S. government changed its policies last December. I’m honored to have been given the opportunity to discuss the credit union movement there, and am reminded of the important work we’re doing back home. The delegation was led by World Council of Credit Unions President/CEO Brian Branch. Former CUNA president/CEO Dan Mica organized the trip of CUNA/League System leaders to help officials there understand how the cooperative business model and changes in that country’s approach to financial policy may open the door for credit unions. You can learn more about World Council’s development efforts in Cuba at

2015 Credit Union Rock Stars:

The 2015 class of Credit Union Magazine’s Rock Stars has been announced. They are an impressive group of people that in their day-to-day work display an unrivaled commitment to the credit union movement. The special edition of the magazine was published yesterday, timed with International Credit Union Day. You can read their stories online at
Thank you for your membership in and engagement with the CUNA/League System.


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