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FDIC Federal Register Citations

From: Tom Procopio [mailto:Tom@bankplace.com]
Sent: Thursday, October 20, 2005 5:29 PM
To: Comments
Subject: ANPR Risk-Based Capital Guideline Modifications

One comment concerning ADC loans: these loans should be eligible for lower percentage based not only on LTV, strength of guarantors, cash equity in the project and/or historic performance with the bank or other banks; one of the most important factors is the pre-sale/leased requirements of the loan agreements; the risk is significantly reduced if pre-sales/leased requirements are tied to debt coverage; for example, no vertical construction is allowed unless XXX per cent of proposed units/rentable space are pre-sold under binding non-refundable contracts; or initial funding is not allowed for the AD portion unless XXX percentage of units are pre-sold under binding non-refundable contracts.


 


Last Updated 10/24/2005 Regs@fdic.gov

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