ALEXANDRIA, Va. (2/20/08)—Credit unions may use different approaches to satisfy a federal requirement that it retain an employee with at least two years experience before launching a member business lending (MBL) program, according to a recent National Credit Union Administration (NCUA) legal opinion letter. The opinion letter was inspired by an inquiry asking whether a credit union must always use the services of a third-party underwriter to satisfy the NCUA’s member business lending (MBL) rule’s two-years-of-direct-experience requirement. NCUA Associate General Counsel Sheila Albin responded that while a credit union may use the services of an outside party, it is not required to do so. It also may use the direct experience of its own employees. Further, wrote Albin, a credit union is not required to hire an individual who has the requisite experience at the time of hiring. It may satisfy the direct experience requirement instead with an employee who has developed the requisite experience over time. However, if a credit union chooses to take the latter course of action, it is subject to certain regulatory limitations. For instance, to qualify an existing employee must be familiar with such things as the proper underwriting, analysis, and origination of MBLs in order to understand their complexity and risk exposure. Use the resource link below to read the NCUA’s entire opinion letter.