Implausible Deniability….

"Brace Yourself." 

The third Thursday of each month should be "hard-wired" into your credit union enterprise risk management (ERM) plan as periods of " code red, heightened risk alert".  Because on those Thursdays, it's highly probable that the NCUA Board will be meeting - as they are today. And of late, when the NCUA Board meets, the credit union movement is in jeopardy.

Playing with matches...

What makes today's NCUA Board Meeting (www.ncua.gov) of particular interest is the proposed risk-based capital (RBC) rule which has drawn a firestorm of controversy and criticism from over 1,000 inflamed commenters, and has attracted a Congressional call for review, signed by over 300 members of the U.S. House of Representatives.

Not sure that we Americans have seen that much unity (over 75%!) at any time, on any subject over the last dozen years! Even several Senators have openly expressed strong reservations about the NCUA RBC proposal.  Sen. Al Franken (D-MN) even went so far as to personally thank NCUA for all the free, ridiculous, comedy routine material, which he can put to good use, if he ever retires and returns to "Saturday Night Live"!

All the major CU trade associations, also, have asked that Chair Matz extend the "Comment Period" (ends May 28, regcomments @ncua. gov) or withdraw the proposed RBC rule entirely, until professional analyses can be conducted of the current and future consequences of the rule. All were reasonable, polite, responsible requests; all were promptly denied by the Chair -  without a vote, without recourse, without dialogue, without provision for appeal.

Careless and reckless?

The risk Ms Matz has created for the Agency is a "mini-Benghazi" crisis scenario. NCUA was careless and reckless in writing the RBC rule putting all CUs at risk. When advised of the massive risk exposure that has been created, the Chair has unilaterally refused to heed the calls for caution and greater protection; and, has so far heightened the risk by failing to act. The looming, threatening results of further inaction - much like Benghazi - appear painfully clear.

Refuse?

But today is the third Thursday of the month; the NCUA Board is meeting; Chair Matz can easily act to extend or withdraw the RBC rule … and provide the intelligent, prudent leadership response required to prevent this pending credit union "Benghazi" firefight….

If the Chair refuses again today, to act to safeguard America's credit unions from this crisis; then at least in the future, there will be no argument about the source of the problem and exactly…

… whose little red wagon it is.