Key takeaway: Industry advocates believe the proposed rule changes are game-changers that could result in the formation of new mutuals, while also convincing some credit unions to consider switching charters. Industry advocates believe the proposed rule changes are game-changers that could result in the formation of new mutuals, while also convincing some credit unions to consider switching charters. The Fed's proposal also ensures that special deposits and mutual capital certificates are treated as regulatory capital, including Common Equity Tier 1 capital in some instances. The proposed rules could also prompt some credit unions to consider converting charters, Weissman and Fraser added. The Fed is accepting comments on the proposed rule changes through Oct. 5.