Additionally, NAFCU continues to hear from its members that the waiver process is complicated and inefficient. Due to this, many credit unions have been unable to extend solid loans to their small-business members. These loans may have been lost to competitors or never provided at all.

The process to obtain a waiver should not be so unreasonably difficult that it prevents credit unions from serving their membership effectively. We believe the NCUA's current detailed list of available waivers should be replaced with a more flexible waiver provision that would allow a credit union to apply for, and obtain, a waiver from a non-statutorily required MBL regulatory requirement.

Also, NAFCU understands that the NCUA expects credit unions to practice appropriate risk assessment and monitoring. However, the waiver requirement that credit unions have a five- year relationship with the borrower and current principals creates an undue burden that doesn't necessarily promote good underwriting or risk assessment. We urge the NCUA to reconsider this requirement for obtaining a waiver of the personal guarantee requirement.

Credit unions have demonstrated their support for small business consistently. A study commissioned by the SBA's Office of Advocacy in 2011 found that bank business lending was largely unaffected by changes in credit unions' business lending, and credit unions' business lending can actually help offset declines in bank business lending during a recession. The study showed that during the 2007-2010 financial crisis, while banks' small business lending decreased, credit union business lending increased as a percentage of their assets. And they continued to do so to the best of their ability under the current restrictive regulatory framework.

Ultimately, while Congress continues to contemplate the possibilities of MBL, the NCUA has the chance to be a true champion for credit unions, well within its regulatory purview, and allow credit unions to fully serve Main Street and their small business members.

As Chairman Matz has noted in the past, MBLs can be an important way to diversify a portfolio. Credit unions have proven their mettle and commitment to their members through the financial crisis, and NCUA's fourth-quarter 2013 call report underscore the solid footing of the industry.

Now is the time to allow credit unions to build on their success and allow them to fulfill their mandate to serve their small-business members to the best of their ability. The fair and reasonable changes suggested by Mr. Fryzel would be an important a step in that direction.

B. Dan Berger

President/CEO

NAFCU

Arlington, Va.