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| They could be barking up the wrong Forrest! (Again!!) |
One would think that more input from credit unions would be critical, especially when the second comment period was granted because there will be "significant structural changes".
Here's what Chair Matz said in the press release (9/29/2014):
"I have always said that another comment period would only be appropriate if we decide to make significant structural changes that would exceed the parameters of the Administrative Procedures Act [APA]."
"Based on discussions with NCUA's General Counsel I now believe it is prudent under the APA to ask for additional comments."
Clearly NCUA staff can use all the help they can get to avoid a repeat of "the recent unpleasantness", resulting from RBC round one!
While credit unions wait to see if we're asked to actually participate, you could help out by sending the NCUA folks some more of the source material from which they apparently choose their "best" ideas....
"... has everything you're looking for!"
- Russell Stover Candies
(It's what Forrest Gump would do!)
6 comments:
My guess is the esteemed chairman is waiting for her term to expire and leave the rest of the board holding the bag. Nothing will be done for the remainder of this year-those hard working folks need some downtime-then another month or so to decide whether to allow another comment period , then announce it ( much to the joy of the villagers), then give "serious" consideration to those comments, have some "listening" tours, re-draft, etc. The final course of action will be to a) spend a few more months coming up with an excuse as to why they have decided there is already a law or reg or Constitution that takes precedence, b) hire more staff to monitor those pesky credit unions, or c) all of the above.
It is amazing that credit unions in America are being flogged to death when in fact they are so member centric and actually add to the strength of our financial system.
Credit unions should not fear any RBC rule that is passed under the Matz regime. Why? Because the rule will have a FOUR year implementation period. The Chairman will be long gone before that time approaches.A more responsive board will look at that rule before it becomes effective and say this is not good and needs to be changed or maybe even put to rest. So all these months of frustration, rhetoric,comments and concern will have been for naught.There is light at the end of the term.
Please, no more listening sessions. I have had enough teachers berate me in grade school. I do not need a Chairman to dress me down in front of my peers because I ask a question she does not like.
Credit union members deserve effective regulations that promote the safety and soundness of their institutions. Accepting a defective regulation with the idea that it will be changed before it is implemented is not in the best interest of the industry. Credit unions and and their regulator have a duty to get it right the first time.
SWEET!
Rumor has it she wanted this to be her "legacy fix" for cu's, as a going away gift, one would have to surmise. She was as receptive to listening as Obama was after the elections... not so much. It was over her objection that we get another go at it. The best part of that is it throws off her time-table. She may run out of job before she gets this through. We still have time to get it right. Also - We should fear this rule --- look how long it's taken to start to alleviate the much touted (AKA let's all sing Kumbaya!) disaster of HR1151.
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