CUNA Regulatory Comment Call

November 19, 2008

Interim Final Rule on Rates and Loan Pools for SBA Loans

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may contact us at 800-356-9655, ext. 6732, if you would like a copy of the interim final rule. You may also access it here.

QUESTIONS TO CONSIDER REGARDING THE SBA INTERIM FINAL RULE

  • Do you believe the changes in the interim final rule allowing loans to be priced based on the LIBOR rate will enhance the ability of small business to access capital through SBA loans? Will the changes be more attractive to credit unions and others lenders who make SBA loans?
















  • Will the changes that allow weighted average coupon pools increase the liquidity for SBA-backed secondary market securities by making it more attractive for investors to purchase these loan pools?
















  • Other comments?
















    Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
    Mary Mitchell Dunn • SVP & Deputy 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
    Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com