Mr. Kevin Johnson:

The 2012 Act effectively empowered the regulator to make rules. Lending limits were embedded in section 35 of the 1997 Act but this was replaced by a provision giving the regulator the authority to set the limits. In the commission report, the expectation was that in transferring that authority from legislation into regulation there would be a thorough review and that under the tiered regime some credit unions would be allowed to do more. In fact, the existing term rules found their way into the regulations and concentration limits, based on different categories of loans, were placed on top of them. A lot of these rules resided in the legislation but are now the remit of the regulator.