November 13, 2012
Khem R. Sharma
Chief, Size Standards Division
409 Third Street SW.
Washington, D.C. 20416
RE: RIN 3245-AG45; Small Business Size Standards
Dear Mr. Sharma:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I write to you regarding the U.S. Small Business Administration’s (SBA) proposed rule to increase small business size standards for a number of industries in the North American Industry Classification System (NAICS). Specifically, I am writing about the aspect of the proposed rule to increase the small business size standards for credit unions from the current $175 million in assets to $500 million. NAFCU strongly supports the proposed rule’s increase of the small business size standard for credit unions.
NAFCU appreciates the SBA’s efforts in conducting the extensive data analysis on small business sizes for various industries. As the SBA correctly concludes in the proposed rule, the data supports increasing the asset threshold for credit unions. The importance of the size standards, as the agency knows, has increased with the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which requires the newly created Consumer Financial Protection Bureau (CFPB) to conduct analysis of the impact of its regulations on small entities. The CFPB analysis is conducted under the Small Business Regulatory Enforcement and Flexibility Act (SBREFA) and relies on the SBA’s small business standards for the purpose of assembling panels made up of affected small entities to study a proposed regulation and issue a report to the CFPB. The proposed increase, we believe, will prove helpful as it would allow access to more voices in the SBREFA process.
NAFCU appreciates the opportunity to comment on this proposed rule. If you have any questions or concerns, please feel free to contact me at (703) 842-2268 or ttefferi@nafcu.org.
Sincerely,
Tessema Tefferi
Regulatory Affairs Counsel