|VA - roooom!|
So what would a normal, reasonable person do in this ever evolving self-inflicted, political disaster? Quit while you're behind - right? Well no, Chair Matz decided to "double-down" and write another
|No noose is|
Again, the key burning issue, for most credit unions in the RBC rule, is the "individual minimum capital requirement" (IMCR), which gives the increasingly erratic leadership of the NCUA unlimited, capricious authority to single out and persecute any credit union - without appeal nor due process provisions.
Chair Matz has taken up the IMCR issue at several different venues, including the listening sessions and in her letters to Representatives McHenry and Hensarling, protesting that the proposed IMCR rule does in fact include full, independent appeal rights for every persecuted credit union through NCUA's Ombudsman. Here's the exact wording from the proposed RBC rule:
747. 2006: Review of order imposing IMCR
"9) Ombudsman. A credit union may request in writing the recommendation of NCUA's ombudsman to modify or to not issue a proposed IMCR..."
|We're always right!|
Well, it looks to me that Ms Matz is right! The proposed rigged-based capital (RBC) rule does in fact permit credit unions to appeal their persecutions through the existing NCUA Office of the Ombudsman process. So, I thought I'd venture over to the official NCUA website (www.ncua.gov - About NCUA/Org. Chart) and take a look at how the ombudsman works. Here's what I found...