CUNA Regulatory Comment Call


July 1, 2004

Proposed Member Business Loan Rule Revision to Enable CUs to Participate More Fully in SBA Loans

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. Are there any other modifications that should be made to the MBL rule so that it is better aligned with the lending programs offered by the SBA?

    Yes ______ No ______

    If yes, what modifications should be made?
















  2. Are there any other modifications (such as changing the loan-to-value definition) to the MBL rule that you think are particularly important to advocate NCUA to make?

    Yes ______ No ______

    If yes, which provisions of the MBL rule should be modified and how?
















  3. The proposal states that although this rulemaking pertains only to SBA guaranteed loan programs, NCUA will consider other government programs as the need arises. Are there other government programs of which NCUA should be aware with regard to the MBL rule?

    Yes ______ No ______

    If yes, which government program(s)?
















  4. Other comments?
















    1. 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
      Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com