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FDIC Federal Register Citations



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FDIC Federal Register Citations
Summit State Bank

From: Doug Haigh [mailto:dhaigh@summitstatebank.com]
Sent: Tuesday, April 04, 2006 5:18 PM
To: Comments
Cc: Terry Davis
Subject: Guidance on Commercial Real Estate Lending

Summit State Bank has reviewed the draft Guidance memorandum and recommends FDIC consider including the following points:

1. Weight concentrations in multi-family properties 50% less than other property types based on fungible demand for residential housing stock.

2. Weight concentrations in other non-owner occupied CRE properties less or exclude from concentration aggregate sum if LTV is under 65%.

3. Describe metrics for allocating additional capital relative to sliding scale of concentration levels.

Thank you for your consideration.

Douglas C. Haigh
SVP/Chief Credit Officer
P.O. Box 6188
Santa Rosa,CA 95406-0188
(707)568-4920
(707)573-4624 (FAX)

 


 Last Updated 04/05/2006 Regs@fdic.gov

Last Updated: August 4, 2024