CUNA Regulatory Comment Call


December 2, 2004

Changes to NCUA Lending Rules
(Not a Major Rule)

EXECUTIVE SUMMARY

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

BACKGROUND

The NCUA Board has a policy of continually reviewing NCUA rules to “update, clarify and simplify existing regulations and eliminating unnecessary and redundant provisions.” As a result of NCUA’s 2003 review, the Board determined that the rules on loan guarantees and loan maturities should be updated to reflect OGC opinions.

DESCRIPTION OF THE PROPOSED RULE

The NCUA Board proposes to revise the lending rules to incorporate a number of OGC interpretations regarding loans guaranteed under state or federal loan guarantee programs, mobile homes, and manufactured homes. Here are the proposed changes:

QUESTIONS TO CONSIDER REGARDING NCUA’s PROPOSAL AMENDING THE LENDING RULES

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 Thomast • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com