A CUNA comment letter to NCUA regarding proposed technical changes for the Community Development Revolving Loan Fund (CDRLF) offers a generally positive breakdown.
The proposal makes some purely technical and reorganizational changes to Part 705, which governs CDRLF, CUNA noted. These changes would remove duplicate definitions included elsewhere in NCUA’s rules and regulations as well as clarify that certain sections apply only to CDRLF loans, and not also to technical assistance grants. CUNA supports the proposed technical changes.
CDRLF provides technical assistance grants and loans to low-income designated credit unions. It also serves as a source of funding to help low-income credit unions respond to emergencies arising in their communities.
CUNA “strongly” supports the amendment to make the concurrence process more efficient for federally insured, state-chartered credit unions (FISCUs). While FISCUs will still need concurrence from state supervisory authorities, they would not need to obtain concurrence before applying for a loan.
“We believe this change would make the overall application process slightly less burdensome for FISCUs,” the letter reads. “This proposed change is an example of a simple shift in process that is unlikely to affect the quality or timing of information to NCUA but may ease the compliance burden on participating credit unions.”