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NAFCU President and CEO Dan Berger wrote NCUA to express the association's appreciation for the proposed member business lending rule that eliminates the waiver process and provides much-needed regulatory relief.

"NAFCU has found that small businesses are struggling to find access to capital and liquidity from other lenders, and are turning to credit unions for help," Berger wrote. "Credit unions want to provide such funding, in a safe and sound manner, but are arbitrarily limited by NCUA's existing regulation."

He continued, "NAFCU and our members would like to express our appreciation to NCUA for engaging in numerous discussions with NAFCU, credit unions and industry representatives on how to amend Part 723 to achieve needed flexibility, while maintaining the safety and soundness of the industry."

Berger also emphasized NAFCU's continued advocacy for broader changes in MBL rules through legislation that would allow an exemption from the MBL cap for more credit unions. He thanked NCUA Chairman Debbie Matz for her support of the "Credit Union Residential Loan Parity Act," and the "Credit Union Small Business Jobs Creation Act," and urged the agency to support legislation that would exempt veterans from the MBL cap (H.R. 1133).

Further, Berger noted that NCUA has the full statutory authority to make this rulemaking because the changes only apply to non-statutorily mandated requirements, instead of the statutory MBL cap. He also made additional recommendations relating to the rule, including that NCUA adopt a 12-month implementation period for the rule.

MBL changes are a major focus of NAFCU's "Top Ten List" of regulations to amend or eliminate and its five-point plan for regulatory relief.