|Caught in the act .… again?|
In the final, poorly plotted chapter, the evil-doer is always identified (it was the butler!) and how the murderous crime was committed (with the candlestick in the billiards room!) is also revealed. These run-of-the-mill authors invariably save the worst for last. The reader hoped for a new, imaginative story line, more deeply drawn characters, and more finely nuanced emotion; but closes the cover - played for a fool once again.
|We're not even good |
The entirely new authority which NCUA awards itself ( for its' stellar, recent record of regulatory performance?) is designated as…
Section 747.2006 - Review of order imposing individual minimum capital requirements (IMCR)
After using up 194 pages (and having a really cute little on-line calculator!) on "patty cake, patty cake" rule writing, which insinuates that 94% of credit unions will be well-capitalized and therefore lulls you into complacency; the NCUA attempts to exempt itself from its own new capital rule…. and in true NCUA fashion, exempt itself from the rule of law in general!!!
You should take the time to read pages 195-198. If you do, you can skip the other 194 pages of cheap fiction, because…
Section 747.2006 overrides all the other supposedly detailed, balanced, new risk-based capital "rules"
(and even disavows that really cute little calculator!).
IMCR simply says that regardless of the capital rules, the NCUA Board may unilaterally impose its own self-created, self-justified, self-serving capital requirements on your credit union … regardless of the rules.
|Well, that's fair!|
You do have the right of course to appeal an arbitrary and capricious "imposition" to…. (you guessed it!)…. to the NCUA!!!
(America's credit unions… played for a fool once again.)