We are a large Wholesale Institution and we would like to increase some of our residential lending to accommodate the following:

- Individuals who have a relationship (e.g. officers, directors or employees) to an existing commercial or corporate customers that have existing depository and/or credit relationships with the bank. Existing relationship shall be defined as customers that have significant relationship with a global branch (including domestic branch) for at least 12 months prior to the origination of the residential mortgage loan.

- High net worth individuals, VIP or private banking clients of the Parent Bank i.e. existing customers who had a relationship with a global branch (including domestic branch) in the amount of at least US $250,000 annual average balance in either savings or time deposits, prior to the origination of the residential mortgage loan.

- Bank Employees

- Individuals who have a relationship (e.g. Officers, directors, employees, principals) to existing vendors, correspondent financial institutions, consulting firms, law firms, and accounting firms, which provide services to the bank.

They will put a cap of no more than 12 per month or 120 per year.
No advertising or marketing.

Do you see any issues with it affecting our wholesale designation or any other regulation?

Thanks

More Info:

Many of these potential customers will be:

foreign individuals who are seeking acquisition financing of residential properties in United States as second home, or as residence for children attending schools in United States.