We applaud NCUA Board Member Michael Fryzel for his leadership and call for the agency to amend the regulations on member business lending. This is indeed an opportune time for the NCUA to proactively pursue amending the MBL regulations that have choked credit unions' ability to help small businesses.

The suggestions Mr. Fryzel highlighted are key parts of NAFCU's "dirty dozen" list of regulations that should be amended or eliminated. Additionally, we believe the NCUA should use its authority granted in the Federal Credit Union Act to provide an exception to the limitations on member business loans for those credit unions that have a history of making MBLs to their members. We believe credit unions that have had a successful MBL program in place for five years or longer should be sufficient to satisfy the statutory requirements. The NCUA should set this standard and make the exception available to all credit unions.

The NCUA should also issue appropriate guidance for compliance with these exceptions. By adopting this change, the agency will be able to increase the availability of safe and sound MBLs in the market, which will benefit both credit unions' members as well as the economy and the industry.