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Does subprime lending only refer to real estate?

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Question: 
I'm a little confused about Subprime lending. Does this apply to all loans or just real estate? Also, do we need to flag our loans for the new call report requirement?
Answer: 

Subprime is not restricted to any particular products. The OCC bulletin 2001-6 says:

"The term “subprime” refers to the credit characteristics of individual borrowers. Subprime borrowers typically have weakened credit histories that include payment delinquencies, and possibly more severe problems such as charge-offs, judgments, and bankruptcies. They may also display reduced repayment capacity as measured by credit scores, debt-to-income ratios, or other criteria that may encompass borrowers with incomplete credit histories. Subprime loans are loans to borrowers displaying one or more of these characteristics at the time of origination or purchase. Such loans have a higher risk of default than loans to prime borrowers. Generally, subprime borrowers will display a range of credit risk characteristics that may include one or more of the following:

  • Two or more 30-day delinquencies in the last 12 months, or one or more 60-day delinquencies in the last 24 months;
  • Judgment, foreclosure, repossession, or charge-off in the prior 24 months;
  • Bankruptcy in the last 5 years;
  • Relatively high default probability as evidenced by, for example, a credit bureau risk score (FICO) of 660 or below (depending on the product/collateral), or other bureau or proprietary scores with an equivalent default probability likelihood; and/or
  • Debt service-to-income ratio of 50% or greater, or otherwise limited ability to cover family living expenses after deducting total monthly debt-service requirements from monthly income.

This list is illustrative rather than exhaustive and is not meant to define specific parameters for all subprime borrowers. Additionally, this definition may not match all market or institution specific subprime definitions, but should be viewed as a starting point from which the Agencies will expand examination efforts.

You may also want to refer to the March 1999 Interagency Guidance on Subprime Lending.

First published on BankersOnline.com 1/20/03

First published on 01/20/2003

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