To make you aware of the positions that NAGGL has taken on SBA’sProposed Rule on Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization, (87 FR 66963), we are sharing a final version of the association’s comment letter.
Whether you agree with NAGGL’s comments, or have different opinions, we urge you to submit your own comment letter reflecting the nuances of your individual points of view. As a last resort, if you agree with our positions on the proposals, you can submit a comment letter that indicates your concurrence with the NAGGL positions. But, that type of submission likely will have far less impact on how SBA drafts its Final Rules than a comment letter that is more personalized. NAGGL has provided additional information on regulatory comment submissions here. The deadline to submit comments on this proposed rule is January 6 at 11:59 PM ET.
As a reminder, lenders must submit separate comment letters on each of the regulatory proposals. If the comment letter you submitted in response to the Affiliation Proposed Rule included your comments on the SBLC Proposed Rule, we recommend that you resubmit that letter through the SBLC Proposed Rule website specifically referencing the SBLC proposal.
You can read the Association’s comment letter on the Proposed Rule regarding Affiliation and Lending Criteria here.
