CUNA Regulatory Comment Call


May 2, 2005

Amendments to NCUA’s MBL Rule

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. Do you agree with the clarification regarding corporate credit union minimum capital requirements for making unsecured MBLs?

    Yes _____ No _____

    Why or why not?
















  2. Do you agree with the amendment to the definition of “construction or development loan”?

    Yes _____ No _____

    Why or why not?
















  3. Do you agree that the phrase “net worth” used in the MBL rule should be revised to be consistent with the definition of that phrase found in the Act and in NCUA’s PCA regulations?

    Yes _____ No _____

    Why or why not?
















  4. Do you believe that NCUA should broaden the MBL rule to enable credit unions to participate more fully in additional government guaranteed loan programs?

    Yes _____ No _____

    If not, why not? If so, would it be better to expand the MBL rule to permit only specifically identified programs or to permit more favorable treatment for loans under all government guaranteed loan programs? NCUA is particularly interested in comments that address the benefits of specific programs and any safety or soundness or operational concerns associated with them.
















  5. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com