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Missouri Federal Lawmakers Share CU Concerns about Risk-Based Capital Proposal

Credit unions are getting support from current and past members of Congress – including those in Missouri – in efforts concerning the National Credit Union Administration’s (NCUA) risk-based capital (RBC) proposal.

All eight of Missouri’s U.S. Representatives, including four serving on the House Financial Services Committee, have signed a letter circulated by U.S. Representatives Peter King (R-NY) and Gregory Meeks (D-NY). The letter raises concerns with the risk-based capital proposal that are consistent with many of the concerns of credit unions, including the economic impact of the proposal, the concentration-based risk-weights and the implementation period. Click here for the letter.

A total of 324 members of the U.S. House (75% of representatives serving) have signed the letter. The Missouri Credit Union Association (MCUA) thanks Missouri 's U.S. Representatives for their support, including:

  • U.S. Rep. William Lacy Clay (D-District 1)
  • U.S. Rep. Ann Wagner (R-District 2)
  • U.S. Rep. Blaine Luetkemeyer (R-District 3)
  • U.S. Rep. Vicky Hartzler (R-District 4)
  • U.S. Rep. Emanuel Cleaver II (D-District 5)
  • U.S. Rep. Sam Graves (R-District 6)
  • U.S. Rep. Billy Long (R-District 7)
  • U.S. Rep. Jason Smith (R-District 8)

In addition, former U.S. Senator Alfonse D’Amato (R-N.Y.) wrote to NCUA on May 12, outlining how the agency would exceed its legal authority if it adopted the RBC proposal. Click here to read the letter. Sen. D'Amato chaired the Senate Banking Committee during the H.R. 1151 battle and led the development of the changes to the Federal Credit Union Act including those on prompt corrective action

Write Your Own RBC Comment Letter

MCUA encourages each credit union with assets of $40 million or more to send a comment letter to NCUA regarding the risk-based capital proposal. The comment deadline is May 28. The Credit Union National Association (CUNA) has created the RBC Action Center, with resources about the proposed rule that make it easier to write a comment letter. A CUNA ID and password is required.

Feel free to reference in your letter that Missouri’s U.S. Representatives share these same concerns and have signed a letter expressing issues with the risk-based capital proposal.


"The risk-based capital proposal will have a negative effect on credit unions. Submitting a comment letter is a great way for your voice to be heard," says John Thomas, MCUA SVP of Compliance. "Later this week, the Missouri Credit Union Association's Compliance department will be sending an email with detailed instructions on how to submit your own comment letter."

MCUA's Regulatory Compliance department is also in the process of writing a letter on behalf of all Missouri credit unions.

An excerpt from the RBC comment letter written by Brandon Michaels, president/CEO of Mazuma Credit Union (Kansas City) was highlighted in a recent article posted on, expressing concern about the risk weights of the RBC proposal.

     Brandon Michaels

“Are you penalizing credit unions who engage in MBLs [member business loans]? Are you trying to regulate credit risk in a capital requirement alone? MBLs are better for ALM because of the repricing structure. So, why is NCUA attempting to deal with interest rate risk through this setup? Ignoring the liability side of the balance sheet is just fundamentally wrong,” wrote Michaels.

The risk-based capital proposal is an issue with far-reaching effects for the credit union industry. Anyone, especially credit union leaders, volunteers, and members, may submit their feedback or opinion to NCUA in any of the following ways:

  • Email NCUA with the subject line “[Your Name] — Comments on Proposed Rule: PCA — Risk-Based Capital”
  • NCUA website
  • Federal eRulemaking Portal
  • Fax to 703-518-6319 and include this on the cover page: “[Your Name] — Comments on Proposed Rule: PCA — Risk-Based Capital”
  • Mail to Gerard Poliquin, Secretary of the Board, National Credit Union Administration, 1775 Duke Street, Alexandria, Virginia 22314-3428
  • Deliver/courier to 1775 Duke Street, Alexandria, Virginia 22314-3428

For more information or assistance, contact the MCUA Compliance department via email or phone, 800.446.3620.