DCUC Raises Credit Union Concerns on Capital Proposals Impacting Main Street Lending

WASHINGTON, DC – Today, the Defense Credit Union Council (DCUC) wrote to leaders of the House Financial Services Committee ahead of the full committee hearing, “Prioritizing Main Street: Evaluating the Impact of Capital Proposals on Economic Growth and American Communities.”

In the letter, DCUC requested the Committee ensure that any recalibration of bank capital requirements is grounded in rigorous, evidence-based analysis and does not create unintended competitive disparities for credit unions. 

DCUC expressed its support for a prudential regulatory framework that is strong, risk-sensitive, and transparent, while cautioning against broad policy shifts that could disrupt access to traditional Main Street lending.  DCUC called attention to the cumulative impact of capital proposals across the financial system, noting differing perspectives among regulators on how recent proposals may affect overall resilience. 

DCUC’s letter outlines several key recommendations for congressional consideration: 

• Requiring a joint cumulative-impact analysis from federal banking agencies before finalizing any capital rule changes, including effects on mortgage lending, small business credit, and market competition. 
• Preserving risk-sensitive treatment of traditional lending activities, ensuring continued access to credit for military families, first-time homebuyers, and veteran-owned businesses. 
• Avoiding mechanical adjustments to global systemically important bank (G-SIB) surcharges that are driven by economic growth factors rather than actual systemic risk. 
• Conducting an interagency parity review to assess how changes to bank capital rules may affect credit unions operating under a separate statutory framework. 

DCUC reiterated the importance of maintaining a level playing field across financial institutions while preserving safety and soundness and requested that its letter be included in the official hearing record.

“Congress must ensure that any changes to capital requirements are driven by data and not arbitrary recalibration, and do not come at the expense of credit unions serving Main Street and military communities,” says Anthony Hernandez, DCUC President/CEO, Ret. USAF Colonel. “If these proposals move forward without a full understanding of the cumulative impact, the result could be reduced access to affordable credit for the very households and small businesses policymakers are trying to support.” 

“Credit unions operate under a distinct, mission-driven model that prioritizes access, affordability, and member service,” says Jason Stverak, DCUC Chief Advocacy Officer. “Any shift in the broader capital framework must account for those differences to avoid tilting the playing field and limiting the ability of credit unions to meet the needs of servicemembers, veterans, and local communities.” ​

DCUC reaffirmed its commitment to working with Congress and regulators to advance a balanced financial system that supports economic growth, consumer protection, and continued access to affordable financial services for those who serve.