Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums Audit FRB -Borrower in custody certification question
Thread Options
#1682829 - 03/27/12 07:23 PM FRB -Borrower in custody certification question
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
I am testing loans eligible to be pledged according to the FRB guidelines.

My question, we have 3-4 large balance (for us)commercial loans that we have a participation agreement with another bank ( we are lead with 75% they are 2nd with 25%). It seems to me we should only be able to pledge the 75% we own.. but I cannot find anything that says this... HELP!

Thank you!

Return to Top
Audit
#1682860 - 03/27/12 08:01 PM Re: FRB -Borrower in custody certification question Chocaholic
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
(7) Loan participations must be clearly structured as purchase-sale transactions and must not contain any assignability restrictions. Participations in loans to the pledging institution's affiliates are not acceptable.

http://www.frbdiscountwindow.org/FRcollguidelines.pdf
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#1682869 - 03/27/12 08:08 PM Re: FRB -Borrower in custody certification question edAudit
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
OK so if it is structured as purchase/sale... we still own 75%, can we pledge that amount?

Return to Top
#1682904 - 03/27/12 08:53 PM Re: FRB -Borrower in custody certification question Chocaholic
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
We do not pledge participant loans at all as we do not have the need to. I would await a more versed response. I was just posting that the 25% not held by your institution is out.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#1683204 - 03/28/12 05:09 PM Re: FRB -Borrower in custody certification question edAudit
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
Thank you for the clarification..

Return to Top

Moderator:  Andy_Z