Date: May 28, 2014
Issue: Risk Based Capital
To: National Credit Union Administration
Filing Type: Regulatory
Description: The CCMC believes that the NCUA needs to address issues related to the application of the Risk Based Capital proposal on Main Street business lending. The inclusion of many smaller credit unions may have additional negative impacts upon Main Street businesses and their growth potentialities. Accordingly, these issues should be addressed the Risk Based Capital proposal is finalized.