CUNA Regulatory Comment Call


November 23, 2005

SBA’s Gulf Opportunity Pilot Loan (GO Loan) Program

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. The interim final amends the definition of eligible “small business” for purposes of the GO Loan Pilot to encompass more businesses in the disaster areas. The new definition is based on net worth and net income.

    Do you agree with the size standards for the GO Loan Pilot?

    Yes ______ No ______

    If not, why not?
















  2. The GO Loan Pilot is open only to lenders that are authorized SBAExpress lenders. Not all credit union 7(a) lenders are approved SBAExpress lenders. Do you think that the GO Loan Program should be open to all SBA 7(a) approved lenders, not just SBAExpress approved lenders?

    Yes ______ No ______

    If not, why not?
















  3. Do you have concerns or suggestions with regard to any other aspects of the GO Loan Pilot?

    Yes ______ No ______

    If yes, what are those concerns or suggestions?
















  4. 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