NEWS: The League has updated its ii Release No. B027 – “Business Loans” – to add a new member business loan (MBL) sample policy. Wisconsin state-chartered credit unions can consider using the sample as a template to help them develop an MBL policy that complies with Wisconsin law.
Wisconsin Office of Credit Unions regulations (DFI-CU §§72.05 & .06) require the boards of state-chartered credit unions to adopt a business loan policy and review it annually if they engage in business lending. The regulations list certain topics that the policy must address. Our new sample policy is designed to cover those required topics, which the ii Release summarizes on pages 6-7.
As you know, all League members enjoy free access to PolicyAid as part of your dues-supported services. PolicyAid offers an online compliance policy library, giving credit unions access to nearly 100 sample policies. However, those samples are tailored to federal law, not Wisconsin law. Wisconsin’s MBL regulations, for example, differ in many significant ways from the NCUA’s rules. The League’s new sample policy is designed to reflect these differences.
As with any sample policy, The League cautions credit unions that they must review this MBL sample policy thoroughly and edit it as needed to match their actual practices and procedures. Credit unions risk liability if their policies include requirements that staff do not follow. For that reason, no credit union should ever adopt a sample policy “as is.” The League’s new MBL sample policy explains, for example: “Language that appears in brackets and in bold should be changed as needed. Consider deleting material that is not relevant to the credit union’s member business lending process.”
If you have questions about MBL regulations, the new sample policy, or any other compliance issues, please contact The League’s Compliance Hotline at (608) 640-4050 or email us at compliance@theleague.coop.