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One Week to CUNA’s MBL Webinar: Comments Due Aug. 31
Monday, August 17, 2015 6:45 AM

Credit union stakeholders have the remainder of August to comment on the National Credit Union Administration’s member business lending (MBL) proposal, with resources available from CUNA on the proposal itself and its effect on credit unions. These resources include CUNA’s webinar on the proposal, which is scheduled for Aug. 20.

The NCUA proposed the MBL rule at its June board meeting. It would remove nearly all MBL regulations not required by the Federal Credit Union Act, and would allow credit unions to write their own policies and limits on collateral and security requirements.

CUNA’s Aug. 20 webinar, scheduled to run from 1 to 2 p.m. (ET), will feature Bill Hampel, chief policy officer; Ryan Donovan, chief advocacy officer; and Lance Noggle, senior director of advocacy. CUNA has also prepared a detailed summary of the proposal.

Comments will be accepted by CUNA until Aug. 24. Specifically, CUNA is interested in feedback on the following questions:

  • Do you believe that the switch from a prescriptive rule to a principle-based rule will provide you more flexibility in making business loans? Why or why not?
     
  • Will the adjustments in the calculations of loans that count for the MBL statutory cap assist your credit union in making more MBLs?
     
  • Does the proposed rule provide you with sufficient clarity to know what will be required in your policies/procedures? How will the proposed rule affect your current lending practices/policies?
     
  • Are you comfortable that your examiner will be able to examine your portfolio and policies utilizing a principle-based rule?
     
  • Does the removal of the waiver process benefit your MBL program?
     
  • Does the distinction between commercial loans and member business loans benefit your MBL program?
     
  • Will your credit union need to create a credit risk rating system or credit grading system in order to comply with the proposed rule?

Comments are due to the NCUA by Aug. 31. Credit unions are especially encouraged to comment on the proposal because a number of bankers have been sending form letters to the agency objecting to the proposal in its entirety. PowerComment can be used, in addition to the standard methods.