CUNA Regulatory Comment Call


September 12, 2006

SBA Lender Examination and Review Fees

EXECUTIVE SUMMARY

DESCRIPTION OF THE PROPOSAL

On-Site Examinations and Reviews

Off-Site Monitoring/Review

SBA’s Other Lender Oversight Expenses

Waiver/Exemption

Billing Process

QUESTIONS REGARDING THE PROPOSAL

  1. Do you feel that it is reasonable to charge Lenders for the direct costs of their individual examination or review expenses?

    Yes ______ No ______

    Please explain.
















  2. Do you agree that the allocation of off-site review expenses based on each Lender’s share of the guaranteed dollars in the entire outstanding SBA portfolio provides for an equitable distribution of SBA costs?

    Yes ______ No ______

    If not, what method would be more equitable?
















  3. DSBA contends that, overall, the agency’s proposed cost allocation methodology would result in fees that are reasonable relative to federal financial institution regulator assessments. Do you believe this is correct?

    Yes ______ No ______

    Please explain.
















  4. Do you agree that the proposal is consistent with the legislative guidance in the amendment to tie fees to the “size of the lender’s portfolio being reviewed, and the time necessary to review the portfolios.”

    Yes ______ No ______

    If not, why not?
















  5. Do the billing and payment processes (including late/delinquency fees) seem reasonable?

    Yes ______ No ______

    Please explain.
















  6. Other comments?
















Eric Richard • EVP &General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Senior 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