Risk-Based Capital Rule 2.0
Even though the Risk-Based Capital Rule 2.0 (RBC 2.0) has been watered-down, it is not good for the industry. Don’t forget a key component of the RBC 2.0 is NCUA’s consideration of adding a separate interest rate risk (IRR) component to risk-based capital.
Standardizing IRR, assumptions, and/or approaches to assumptions, guarantees that the unique risk of an individual credit union will not be captured appropriately. Standardization does not change the need for examiners and credit union decision‐makers to understand the unique risk of an individual credit union.
We will be posting a comprehensive draft of our comments on Tuesday, April 21, 2015.
