MBL Comment letter, Chessen version April 29 2003

1120 Connecticut Avenue, NW Washington, DC 20036 1-800-BANKERS www.aba.com World-Class Solutions, Leadership & Advocacy May 6, 2003 Since 1875 Ms. Becky Baker Edward L. Yingling Executive Vice President Secretary of the Board Tel: 202-663-5328 National Credit Union Administration Fax: 202-663-7533 Email: eyinglin@aba.com 1775 Duke Street Alexandria, VA 22314-3428 Re: National Credit Union Administration; 12 CFR Parts 702, 704, 712, 723 Prompt Corrective Action; Corporate Credit Unions; Credit Union Service Organizations; Member Business Loans; 68 Federal Register 16450, April 4, 2003 Dear Ms. Baker: The American Bankers Association (“ABA”) is responding to the proposed rule published by the National Credit Union Administration (“NCUA”) concerning amendments to its Member Business Loan regulations. ABA strongly opposes the proposed changes in NCUA’s Member Business Loan (“MBL”) rule and believes these proposed amendments are contrary to Congressional intent to limit business lending by credit unions. The ABA brings together all categories of banking institutions to best represent the interests of this rapidly changing industry. Its membership—which includes community, regional, and money center banks and holding companies, as well as savings associations, trust companies, and savings banks—makes ABA the largest banking trade association in the country. Background NCUA adopted its first MBL rule in April ...