This RegBite covers the commercial real estate lending requirements applicable to Federally insured credit unions (FICUs) under 12 CFR part 723. Compliance professionals will gain a working understanding of NCUA's principles-based commercial lending framework, from Board policy approval and staffing obligations through collateral standards, construction loan controls, the aggregate member business loan cap, and prohibited activities.
Topics covered include:
- Scope and applicability under 12 CFR part 723, including simplified compliance thresholds and excluded loan types;
- Board and senior management responsibilities, including policy approval cadence and staffing oversight;
- Commercial loan policy content and structure, underwriting standards, and concentration limits;
- Collateral requirements, unsecured loan conditions, and personal guarantee obligations;
- Construction and development loan definitions, collateral valuation, and disbursement controls;
- Aggregate member business loan (MBL) cap, net MBL balance calculation, and statutory exemptions; and
- Prohibited activities, including ineligible borrowers, equity and joint venture arrangements, and third-party conflicts of interest.
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