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#78456 - 05/06/03 06:42 PM Interest Rate Buydown
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Would an interest rate buy-down for a director, made subject to the same fees and conditions as to anyone else, have to be reported to the Board of Directors? The curious thing is that the loan was sold to Fannie Mae, and they require a new account number. This gives the "appearance" of a new loan even though we do not extinguish the original note. It is considered an modification. Any chance that assigning the new account number could throw a monkey-wrench into an examiners opinion about this under Reg O, i.e. that it is a new loan?

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#78457 - 05/07/03 12:46 PM Re: Interest Rate Buydown
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,293
Galveston, TX
If the loan was sold and is not on the bank's books, I'm not sure what the problem may be?
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