Draft Response to RBC 2.0
April 21, 2015
As promised in last week’s blog post, our draft response to RBC 2.0 can be found here.
Our main objective in writing this response is to convince NCUA that it would be dangerous for the industry, regardless of the chosen methodology, to add an interest rate risk (IRR) component to the proposed rule. IRR is a highly-complex risk with many interdependent components.
We welcome any questions you may have regarding our response.