CUNA Submits RBC2 Comment Letter
CUNA has reiterated in the comment letter it submitted to NCUA that RBC2 is unnecessary and should be withdrawn. CUNA asserts that NCUA has no legal authority to establish a two-tiered RBC structure, and that there is no evidence that had RBC2 been in place prior to the financial crisis that the losses would have been less. CUNA also offers additional recommendations for revisions to the proposed rule. [4/20/15]