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FIL-39-05 Attachment Page 8

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Summary

The Agencies expect institutions to account for and report derivative loan commitments and forward loan sales commitments as derivatives in accordance with GAAP, which includes the use of valuation techniques that are reasonable and supportable in the determination of fair value. An institution's failure to account for and report derivative loan commitments and forward loan sales commitments in regulatory reports in accordance with GAAP may be an unsafe and unsound practice.