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FDIC Federal Register Citations

From: Chaloux, Joseph G.
Sent: Wednesday, December 14, 2005 1:39 PM
To: Comments
Subject: CRA Joint Notice - RIN 3064-AC97

I do have some comments for your consideration.

Regarding the general discussion of extending the "lag period" for one year… I would suggest that something more general be used.

For loan products - I would recommend that we qualify the loan if documentation indicates that the application was received and management had begun underwriting prior to the designation changing (assuming the loan qualifies otherwise).

For investments - I would recommend that the book value of the investment be considered each year just like any other type of equity investment and donations would be considered in the evaluation period when given (just like other donations). A lag time for investments may be appropriate for things like SBIC products but most investments are funded shortly after a decision is made to become involved in the investment/donation. Investments which remain on the bank's books should be viewed just like any other investment even if the declaration or designation is changed. At a minimum they should clarify the lag period would only apply to the intitial qualification and not ongoing consideration (when appropriate).

Joseph G. Chaloux
Senior Compliance Examiner
Federal Deposit Insurance Corp.
Phone - (508) 698-0361 ext 8048

 

 


Last Updated 12/15/2005 Regs@fdic.gov

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