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NCUA's second risk-based capital proposal is in today's Federal Register, with comments due to the agency by April 27.

This proposal would set RBC requirements for "complex" federally insured credit unions and is a rule NAFCU believes is unnecessary and "will only impose more regulatory burden on an already extremely well-capitalized industry," according to the association's Regulatory Alert.

NAFCU is asking members to provide their input to the association by April 3. The Regulatory Alert, published last week, highlights NAFCU's concerns about the proposed rule's impact on credit unions' capital buffer. "Despite NCUA's claim that only a limited number of credit unions will be impacted, this proposal would force credit unions to hold hundreds of millions of dollars in additional reserves to achieve the same capital cushion levels that they currently maintain," it says.

NAFCU is reviewing all aspects of the proposed rule. Last week, the association released its new member-only RBC calculator with a feature that NCUA doesn't include on its own version: five-year forecasting based on estimated return on assets and asset growth rates.

The association is also preparing talking point for credit unions to help them formulate their comments to both NAFCU and NCUA.