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NAFCU is encouraging member credit unions to submit comment letters to NCUA on its member business lending proposal, and it offers a set of talking points they can use in doing so. Comments are due to NCUA Aug. 31.

The NCUA Board released a proposed rule in June that would remove the current waiver process. Instead of the prescriptive measures in place now, the rule would permit credit union boards to establish a principles-based risk management policy addressing their commercial and business lending activities. If the proposal is made final, credit unions would be examined for their adherence to such principles.

Alicia Nealon, NAFCU's director of regulatory affairs, emailed members Monday about the talking points (login required) on the proposed rule. She noted that while the proposed rule offers no relief from the current MBL cap – a statutory requirement – it is "as an important step toward regulatory relief," particularly through its elimination of the need to obtain waivers for some aspects of MBL.

The need for credit unions to provide input is great. Nealon points out that banking trades have their members writing NCUA in droves on the proposed MBL rule changes.

"While NAFCU is busy in Washington disproving the bankers' misinformed attacks, it vital that credit unions weigh in on this proposal to ensure that NCUA knows how important this relief will be," Nealon urged.

The talking points – which offer several helpful arguments according to topic – are just a tool, and Nealon emphasizes that letters should reflect the views of the individual credit unions submitting them.

Members with questions about the proposed rule can contact Nealon directly by phone at 703-842-2266, or send an email to anealon@nafcu.org.