Editor's Note: this letter was written in response to CU Journal Editor in Chief Lisa Freeman's recent column on whether NCUA might wind up "tuning out" some of the more than 2,100 comments filed on the agency's risk-based capital rule, many of which could be summed up as "we really hate this rule."

I assure you that I will not tune out the "we really hate this rule&" comments because, in my view, [the revised proposed rule on risk-based capital] RBC2 not only violates the express language of the Federal Credit Union Act, it's simply not needed, as the proposed rule relentlessly and unfairly punishes a credit union community that was in no manner responsible for the recent financial crisis. As a person who has invested a professional lifetime working around the [too-big-to-fail banks] TBTFs and studying the financial crisis as a member of the TARP Congressional Oversight Panel, let me assure you that credit unions operate under an entirely different business model that stresses member service instead of return to shareholders. It's a fundamentally different approach that yields an inherently unique risk profile that merits thoughtful and specifically targeted regulation on behalf of NCUA. The agency should exhibit the confidence and leadership to regulate credit unions as such and not subject the community to an FDIC-centric one-size-fits-all approach geared to institutions that truly present a systemic risk to the broader economy.

J. Mark McWatters, Board Member
NCUA, Alexandria, Va.