Themis Consultants, Inc
Themis Banner.png

The Themis Update

Policy, Regulations, and Rulings:
The Inside Scoop

NCUA removes occupancy requirement for 1-4 unit dwellings expanding exclusions under BML

Pursuant to the Economic Growth Act enacted on May 24, 2018, the Board of the NCUA revised its final rule to remove from the business member loans all extensions of credit secured by a 1-to-4-unit family dwellings.  As such, these loans will not count towards the aggregate member business loan cap imposed on each federally insured credit union.

Formerly the real estate secured loans were only excluded if the 1-to-4 unit family dwellings were "the primary residence of a member."  That "occupancy requirement has now been removed expanding the exclusion to all 1-to-4 unit family dwelling real estate secured loans. 

The final rule, available online here, will become effective upon publication in the Federal Register.