Comment on NCUA MBL Proposal
Thursday, August 13, 2015
NCUA's Member Business Lending Proposal would make significant changes to how credit unions offer business loans to their members. CCUL Compliance urges MBL credit unions to review proposal details and prepare comment letters, which are due by Monday, August 31. Here are helpful tools courtesy of and in partnership with CUNA:
Free Member Business Lending Webinar - August 20: In a free August 20 webinar, CUNA Chief Economist Bill Hampel, Senior Director of Advocacy Lance Noggle, and Chief Advocacy Officer Ryan Donovan will offer details on the proposal and information to help you write your comment letter. See more on the NCUA MBL Proposal webinar, and register here.
NCUA's MBL Proposal Background: The proposed rule, which has an 18-month implementation period, would completely overhaul NCUA's MBL regulation by:
- Removing almost all requirements not in the Federal Credit Union Act.
- Creating a category of "commercial" loans for safety and soundness purposes while using the category of MBLs for compliance with the Act's limitations on member business lending.
- Removing all of the specific requirements that currently require waivers, including the personal guarantee requirement.
- Exempting some CUs with less than $250 million in assets from the board of director and management responsibility requirements and commercial loan policy requirements.
For more background, review the Federal Register Notice and CUNA's Detailed Summary.
Use PowerComment: The PowerComment online tool offered by CUNA provides seven questions to consider, an opportunity to post additional questions and discussion for other commenters, template letter content for your customization, and a copy of your final letter via email to you. Because your perspective is essential to the League’s own comment letter, we ask that you forward the copy you receive from PowerComment—or your own if written independently—to email@example.com.