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#204760 - 06/25/04 08:51 PM Non-Conforming Loans (LTV)
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
Is there a requirement for non conforming loans to be reviewed by the board.

I prepare a report quarterly...."it's always been done that way". When I called the Senior Lender for a listing of additional collateral on a loan that he had, he said it was time to quit sending that report to the board. He said they don't look at it....

I was under the impression that review was at least quarterly......

If there is a requirement, please let me know where I can get something in writing....We are FDIC governed.

Thanks,

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General Discussion
#204761 - 06/28/04 06:52 PM Re: Non-Conforming Loans (LTV)
Nameless Offline
100 Club
Joined: Apr 2003
Posts: 249
Chaos
This is from the Interagency Guidelines for Real Estate Lending Policies:

Loans in Excess of the Supervisory Loan-to-Value Limits.
The agencies recognize that appropriate loan-to-value limits vary not only among categories of real estate loans but also among individual loans. Therefore, it may be appropriate in individual cases to originate or purchase loans with loan-to-value ratios in excess of the supervisory loan-to-value limits, based on the support provided by other credit factors. Such loans should be identified in the institution's records, and their aggregate amount reported at least quarterly to the institution's board of directors.


Exceptions to the General Lending Policy. Some provision should be made for the consideration of loan requests from creditworthy borrowers whose credit needs do not fit within the institution's general lending policy. An institution may provide for prudently underwritten exceptions to its lending policies, including loan-to-value limits, on a loan-by-loan basis. However, any exceptions from the supervisory loan-to-value limits should conform to the aggregate limits on such loans discussed above. The board of directors is responsible for establishing standards for the review and approval of exception loans. Each institution should establish an appropriate internal process for the review and approval of loans that do not conform to its own internal policy standards. The approval of any such loan should be supported by a written justification that clearly sets forth all of the relevant credit factors that support the underwriting decision. The justification and approval documents for such loans should be maintained as a part of the permanent loan file. Each institution should monitor compliance with its real estate lending policy and individually report exception loans of a significant size to its board of directors.

You can find this at 12 CFR 365 for FDIC regulated banks.
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