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Performance Trust Response Letter to NCUA

April 15, 2014
Bart Smith

As Bart Smith promised in his recent Disciplined Investor article, “NCUA Risk-Based Capital Rules: A Comparison” (February 18, 2014, Volume 7), we have formulated our official response to the recent proposal regarding potential changes to credit union capital measures. Please find our letter attached. While we suggest a number of changes to various parts of the proposal, our overall view is that the proposal is highly inconsistent with the Basel III standards for banks and that it could create serious negative consequences for the credit union industry, if implemented as suggested.

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