LOANS TO ONE BORROWER

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1 LOANS TO ONE BORROWER Carla Stone Witzel Financial Services Practice Group A. National Banks. Effective July 21, 2012, the Office of the Comptroller of the Currency ( OCC ) issued an interim final rule to revise its regulation governing national bank lending limits to consolidate the national bank and savings association lending limit rules. The interim final rule also implements section 610 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which amends the definition of loans and extensions of credit to include credit exposure arising from derivative transactions, repurchase agreements, reverse repurchase agreements, securities lending transactions and securities borrowing transactions. 77 Fed. Reg (June 21, 2012). The lending limit does not apply to the credit exposure arising from a derivative transaction or securities financing transaction until January 1, Id. 1. Purpose and Scope. a. Purpose. The purpose of the federal law, located at 12 U.S.C. 84 (also known as Revised Statutes 5200), and its implementing regulation at 12 C.F.R. Part 32, is to protect the safety and soundness of national banks and savings associations by preventing excessive loans to a single borrower (or to that borrower together with persons related to the borrower through common control or financial interdependence) and to promote diversification of loans and equitable access to banking services. 12 C.F.R. 32.1(b). b. Scope. The lending limits apply to all loans and extensions of credit made by national banks, federal and state savings associations, and their domestic operating subsidiaries. They do not apply to loans made to affiliates as defined in 12 U.S.C. 371c(b)(1) and (e) and Regulation W, to operating subsidiaries, to Edge Act or Agreement Corporation subsidiaries, or to any

2 Page 2 other subsidiary consolidated with the bank or savings association under Generally Accepted Accounting Principles (GAAP). 12 C.F.R. 32.1(c)(1). c. Other Laws that Still Apply. 2. Definitions. Even when a loan complies with the lending limits summarized here, several other laws or requirements must be consulted: the investment limits in 12 U.S.C. 24 (Seventh) or 12 U.S.C. 1464(c), and 12 C.F.R. parts 1 and ; the restrictions on loans to insiders in 12 U.S.C. 375a and 375b; and the overriding rule that all loans may be made only if consistent with safe and sound banking practices. 12 C.F.R. 32.1(c)(2)-(3). a. Appropriate federal banking agency means the OCC in the case of a national bank or federal savings association and the FDIC in the case of a state savings association. 12 C.F.R. 32.2(a). b. Borrower means a person who is named as a borrower or debtor in a loan or extension of credit ; a person to whom a national bank or savings association has credit exposure arising from a derivative transaction or a securities financing transaction entered by the bank or savings association; and any other person, including drawers, endorsers and guarantors, who are deemed to be a borrower under the direct benefit or common enterprise tests (see A.9 below). 12 C.F.R. 32.2(b). c. Capital and Surplus means the sum of: (1) Tier 1 and Tier 2 capital included in its risk-based capital as reported in the Call Report; plus (2) The balance of the allowance for loan and lease losses not included in Tier 2 capital under its risk-based capital calculation as reported in the Call Report. 12 C.F.R. 32.2(c). d. Credit derivative has the same meaning as this term has in 12 C.F.R. Part 3, Appendix C, Section C.F.R. 32.2(i). e. Derivative transaction includes any contract, agreement, swap, warrant, note, or option that is based, in whole or in part, on the value of, any interest in, or any quantitative measure or the occurrence of any event relating to, one or more commodities, securities, currencies, interest or other rates, indices, or other assets. 12 C.F.R. 32.2(k). f. Effective margining arrangement means a master legal agreement governing derivative transactions that requires the counterparty to post, on

3 Page 3 g. a daily basis, variation margin to fully collateralize that amount of the bank s net credit exposure to the counterparty that exceeds $1 million created by the derivative transactions covered by the agreement. C.F.R. 32.2(l). h. Eligible credit derivative means a single-name credit derivative or a standard, non-tranched index credit derivative, subject to certain conditions. 12 C.F.R. 32.2(m). i. Eligible national bank or eligible savings association means a national bank or savings association that is well capitalized as defined in the prompt corrective action rules applicable to the institution and has a composite CAMEL rating of 1 or 2, with an asset quality and management rating of at least C.F.R. 32.2(n). j. Loans and Extensions of Credit (collectively, loans ) are direct or indirect advances of funds to a borrower made on the basis of any obligation of that person to repay the funds, including loans repayable from specific property pledged by or on behalf of the person, and any credit exposure, as determined pursuant to 12 C.F.R. 32.9, arising from a derivative transaction or a securities financing transaction. 12 U.S.C. 84(b)(1); 12 C.F.R. 32.2(q). (1) Loans include: (a) (b) (c) A contractual commitment to advance funds, as defined in 12 C.F.R. 32.2(g); A maker s or endorser s obligation that arises from the discount of commercial paper; A national bank s or savings association s purchase of thirdparty paper subject to an agreement that the seller will repurchase the paper upon default or at the end of a stated period. The amount of the bank s or savings association s loan is the total unpaid balance of the paper owned by the bank or savings association less any dealer reserves retained by the bank or savings association and held as collateral security. Where the seller s obligation to repurchase is limited, the loan is measured by the total amount of the paper the seller ultimately may be obligated to repurchase. A national bank s or savings association s purchase of third party paper without direct or indirect recourse to the seller is not a loan or extension of credit to the seller.

4 Page 4 (d) (e) (f) (g) Overdrafts, but not including intra-day overdrafts for which payment is received before close of business; Sales of Fed funds with a maturity of more than one business day, other than those sold under a continuing contract; Loans charged off the books of the bank or savings association in whole or part; however, charge-offs due to the following circumstances do not fall under this rule: loans unenforceable due to a discharge in bankruptcy, statute of limitations or a judicial decision and loans no longer enforceable for other reasons (like legally enforceable forgiveness) provided the bank or savings association has adequate records and charges-off the loan; [to be removed 1/1/13, 77 Fed. Reg ] A national bank s or savings association s purchase of securities subject to repurchase at the end of a stated period, but not including a national bank s or savings association s purchase of Type I securities, subject to a repurchase agreement, where the purchasing bank or savings association has assured control over or has established its rights to the Type I securities as collateral. 12 C.F.R. 32.2(q)(1). (2) Loans do not include: (a) (b) (c) Additional funds advanced for the benefit of the borrower for taxes, insurance, utilities, security and maintenance and operating expenses necessary to preserve the value of real property when consistent with safe and sound banking practices and when made only for the protection of the bank s or savings association s interest in the collateral; provided, however, that such amounts must be treated as a loan if a new loan is made to the borrower; Accrued and discounted interest on an existing loan, including capitalized interest from prior notes and interest advanced by agreement; Financed sales of the bank s or savings association s own assets, including Other Real Estate Owned, if it does not worsen the bank s or savings association s position;

5 Page 5 (d) (e) (f) Renewal or restructuring of a loan as a new loan following reasonable efforts to bring the loan into compliance with the lending limits, unless new funds are advanced other than in the situation of a qualified commitment to lend (see A.4.c below), a new borrower replaces the prior borrower or the appropriate federal banking agency determines that the renewal was undertaken to evade the lending limits; Amounts paid against uncollected funds in the normal process of collection; and Portions of a participation loan sold on a nonrecourse basis, provided that the participation results in a pro-rata sharing of credit risk proportionate to the participants respective interests as long as certain other conditions are met: (i) (ii) When payments must be applied first to portions sold, pro-rata sharing exists only if the agreement provides that in the event of default, participants must share in all subsequent payments proportionate to their respective interests; and When the originating bank or savings association funds the entire loan, it must receive funding from participants before the close of the next business day, provided, however, that if this condition is not met, the amount funded will be treated as a nonconforming loan rather than a violation if certain other conditions are met. 12 C.F.R. 32.2(q)(2). k. Person means an individual, sole proprietorship, partnership, joint venture, association, trust, estate, business trust, corporation, not-for-profit corporation, limited liability company, sovereign government, agency, instrumentality or political subdivision thereof, or any similar entity or organization. 12 U.S.C. 84(b)(2); 12 C.F.R. 32.2(r). l. Residential housing units mean: (1) Homes (including a dwelling unit in a multi-family residential property such as a condominium or a cooperative). (2) Combinations of homes and business property (i.e., a home used in part for business).

6 Page 6 (3) Other real estate used for primarily residential purposes other than a home (but which may include homes).combinations of such real estate and business property involving only minor business use (i.e., where no more than 20% of the total appraised value of the real estate is attributable to the business use). (4) Farm residences and combinations of farm residences and commercial farm real estate. (5) Property to be improved by the construction of such structure. (6) Leasehold interests in the above real estate. 12 C.F.R. 32.2(x). m. Securities financing transaction means a repurchase agreement, reverse repurchase agreement, securities lending transaction, or securities borrowing transaction. 12 C.F.R. 32.2(aa). 3. General Limits. a. Total loans outstanding to any person at any one time cannot exceed: (1) 15% of the Bank s or Savings Association s Capital and Surplus. When the loans are not fully secured by collateral having a market value at least equal to their face amount; and (2) An Additional 10% of the Bank s or Savings Association s Capital and Surplus. When the amounts over 15% are fully secured at all times by a perfected security interest in readily marketable collateral as defined in 12 C.F.R. 32.2(v) (e.g., financial instruments and bullion that are saleable with reasonable promptness at a fair market value determined by quotations). 12 C.F.R. 32.3(a). b. For purposes of determining compliance, calculations shall be made when the bank s or savings association s Consolidated Report of Condition and Income is required to be filed and if there is a change in capital category. The appropriate federal banking agency also has the right to require recalculation by written notice for reasons of safety and soundness. 12 C.F.R

7 Page 7 4. Special Limits. a. Additional 10% of the Bank s or Savings Association s Capital and Surplus. In addition to the amount allowed under the General Limits (A.3.a. above), the bank or savings association may make loans to one borrower not exceeding 10% of capital and surplus on loans: (1) Secured by livestock or dairy cattle in an amount equal to at least 115% of the amount of the loan that exceeds the combined general limit (appraisals should be completed at least once each 12 months), and subject to special rules in states where persons furnishing pasturage have liens on the livestock, 12 C.F.R. 32.3(b)(3): (2) That arise from the discount of paper by dealers in dairy cattle given in payment for the cattle carrying full recourse endorsements or unconditional guaranties of the seller, and only if the paper is secured by the cattle, pursuant to liens that allow the bank or savings association to maintain a perfected security interest in the cattle, 12 C.F.R. 32.3(b)(4); or (3) That arise from the discount of installment consumer paper, as defined in 12 C.F.R. 32.2(f), carrying full recourse endorsements or unconditional guaranties by the transferor, with additional rules: limiting application of this higher lending limit to the maker where the bank is relying primarily on the maker of the paper for payment; and imposing recordkeeping requirements where paper is purchased in substantial quantities, 12 U.S.C. 84(c)(8); 12 C.F.R. 32.3(b)(2). b. Additional 35% of the Bank s or Savings Association s Capital and Surplus. In addition to the amount allowed under the General Limits (A.3.a. above), a bank or savings association may make loans to one borrower not exceeding 35% of capital and surplus where the loans are secured 115% at all times by bills of lading, warehouse receipts or similar documents transferring or securing title to readily marketable staples as defined in 12 C.F.R. 32.2(w). The staples should be fully covered by insurance if customary to do so. 12 U.S.C. 84(c)(3); 12 C.F.R. 32.3(b)(1). Other conditions as to form and holding of receipts, etc., apply.

8 Page 8 (1) Staples are limited to what are typically thought of as nonperishable agricultural commodities and metals. 12 C.F.R (w), 32.3(b)(1)(ii). (2) The special limit applies to a loan arising from a single transaction or secured by the same staples, provided further that the loan is for a period between 6 and 10 months. 12 C.F.R. 32.3(b)(1)(iii). c. Advances Pursuant to Renewal of a Qualifying Commitment to Lend. The bank or savings association may renew a qualifying commitment to lend, as defined in 12 C.F.R. 32.2(t), and complete funding under the commitment if: (1) Funding is consistent with safe and sound banking practices and is made to protect the bank s or savings association s position; (2) Funding enables the borrower to complete the project for which the qualifying commitment to lend was made; and (3) The amount of funding does not exceed the unfunded portion of the bank s or savings association s qualifying commitment to lend. 12 C.F.R. 32.3(b)(5). d. Savings Associations - Commercial paper and corporate debt securities. In addition to the amount allowed under the savings association s General Limits (A.3.a. above), a savings association may invest up to 10% of unimpaired capital and unimpaired surplus in the obligations of one issuer evidenced by commercial paper or corporate debt securities that are, as of the date of purchase, investment grade. 12 C.F.R. 32.3(d)(3). e. Special Rules for Residential real estate loans, small business loans, and small farm loans ( Supplemental Lending Limits Program ). (1) In addition to the amount that a national bank or savings association may lend to one borrower under the General Limits (A.3.a. above), an eligible national bank or eligible savings association may make: (aa) residential real estate loans or extensions of credit to one borrower in the lesser of 10% of its capital and surplus or the percent of its capital and surplus, in excess of 15%, that a state bank is permitted to lend under the state lending limit that is available for residential real estate loans or unsecured loans in the state where the main office of the

9 Page 9 national bank or home office of the savings association is located. Any such loan must be secured by a perfected first lien security interest in 1-4 family real estate in an amount that does not exceed 80% of the appraised value of the collateral at the time the loan or extension of credit is made. (bb) small business loans to one borrower in the lesser of 10% of its capital and surplus or the percent of its capital and surplus, in excess of 15%, that a state bank is permitted to lend under the state lending limit that is available for small business loans or unsecured loans in the state where the main office of the national bank or home office of the savings association is located. (cc) small farm loans to one borrower in the lesser of 10% of its capital and surplus or the percent of its capital and surplus, in excess of 15%, that a state bank is permitted to lend under the state lending limit that is available for small farm loans or unsecured loans in the state where the main office of the national bank or home office of the savings association is located. (2) The total outstanding amount of a national bank s or savings association s loans and extensions of credit to one borrower made under 32.3(a) and (b) (General Limits and Special Limits), together with loans and extension of credit to the borrower made pursuant to paragraph (1) shall not exceed 25% of capital and surplus. (3) The total outstanding amount of a national bank s or savings association s loans to all of its borrowers made pursuant to the supplemental lending limits provided in paragraph (1) may not exceed 100% of the bank s or savings association s capital and surplus. 12 C.F.R No Limits. The following are not subject to the lending limits: a. Loans arising from the discount of commercial or business paper evidencing a recourse obligation to the person negotiating it, given in payment for the purchase price of commodities in domestic or export transactions, 12 U.S.C. 84(c)(1), 12 C.F.R. 32.3(c)(1);

10 Page 10 b. The acceptance of drafts eligible for rediscount under 12 U.S.C. 372 and 373 or 12 U.S.C. 1464(c)(1)(M) or the purchase of the type of banks or savings associations acceptances that are eligible for rediscount under those sections, but not including acceptance of drafts ineligible for rediscount, a purchase of ineligible acceptances created by other banks or savings associations, and a bank s or savings association s purchase of its own acceptances, 12 U.S.C. 84(c)(2), 12 C.F.R. 32.3(c)(2); c. Loans fully secured by a perfected security interest in bonds, notes, certificates of indebtedness, T-bills, or other obligations fully guaranteed as to principal and interest by the United States and loans fully guaranteed as to the repayment of principal by the full faith and credit of the U.S. government, 12 U.S.C. 84(c)(4), 12 C.F.R. 32.3(c)(3); d. Loans to, or loans secured by unconditional takeout commitments or guarantees of, any department, agency, etc. of the United States, or of any corporation wholly owned by the United States, so long as in the case of a commitment or guarantee, it is payable in cash upon 60 days demand, 12 U.S.C. 84(c)(5), 12 C.F.R. 32.3(c)(4); e. Loans to a state or political subdivision or to the extent guaranteed by a state or political subdivision, provided in either case that an opinion of counsel is received that the undertaking is valid and enforceable, 12 C.F.R. 32.3(c)(5); f. Loans secured by a perfected security interest in a segregated deposit account in the lender, 12 U.S.C. 84(c)(6), 12 C.F.R. 32.3(c)(6); g. Loans to any financial institution or any receiver, conservator, superintendent of banks or savings associations or other agent in charge of the business or property of such financial institution when approved by the appropriate Federal banking agency, 12 U.S.C. 84(c)(7), 12 C.F.R. 32.3(c)(7); h. Loans to the Student Loan Marketing Association, 12 U.S.C. 84(c)(10), 12 C.F.R. 32.3(c)(8); i. A loan to an industrial development authority or similar public entity ( IDA ) created to construct and lease a plant facility (including a health care facility) to an industrial occupant will be deemed to be a loan to the lessee, and not the IDA, if: (1) The bank or savings association evaluates the creditworthiness of the lessee before the loan is made;

11 Page 11 (2) The IDA s liability is limited solely to whatever interest it has in the facility; (3) The IDA s interest is assigned to the bank or savings association as security or the lessee issues a promissory note to the bank or savings association that provides greater security than assignment of the lease; and (4) The lease and rental payments are assigned and paid directly to the bank or savings association. 12 C.F.R. 32.3(c)(9); j. A loan to a leasing company for purchasing equipment for lease will be deemed to be a loan to the lessee, and not the leasing company, if: (1) The bank or savings association evaluates the creditworthiness of the lessee before the loan is made; (2) The loan is without recourse to the leasing company; (3) The bank or savings association is given a security interest in the equipment and, in the case of default, may proceed directly against the equipment and the lessee for deficiencies; (4) The leasing company assigns all of its rights in the lease to the bank or savings association; (5) The lease payments are assigned and paid to the bank or savings association; and (6) The lease terms are subject to the same limits that apply to a national bank or savings association acting as a lessor. 12 C.F.R. 32.3(c)(10). k. Credit exposures arising from securities financing transactions in which the securities being financed are certain governmental securities: Type I securities, as defined in 12 C.F.R. 1.2(j), in the case of national banks; or securities listed in sections 5(c)(1)(C), (D), (E), and (F) of HOLA and general obligations of a state or subdivision as listed in section 5(c)(1)(H) of HOLA, 12 U.S.C. 1464(c)(1)(C), (D), (E), (F), and (H), in the case of savings associations. 12 C.F.R. 32.3(c)(11). l. Intraday credit exposures arising from a derivative transaction or securities financing transaction. 12 C.F.R. 32.3(c)(12).

12 Page Alternative Savings Association Limits. (1) In lieu of the General Limits (A.3.a. above), savings associations may make loans to one borrower for any purpose, not exceeding $500,000, HOLA 5(u)(2)(A)(i), 12 C.F.R (d)(1) (BUT SEE OTHER RESTRICTIONS, e.g., HOLA 5(c)(2)(B)(i)); or (2) Loans to develop domestic residential housing, not exceeding the lesser of $30,000,000 or 30% of unimpaired capital and surplus (including all loans made under the General Limits (A.3.a. above)), if: (a) (b) (c) (d) (e) (f) The savings association is and will be in compliance with fully phased-in capital standards; The appropriate Federal banking agency permits; Such loans to all borrowers do not exceed 150% of unimpaired capital and surplus; and The loans comply with applicable loan-to-value requirements. The term to develop includes each of the various phases necessary to produce housing units as an end product, such as acquisition, development and construction; development and construction; construction; rehabilitation; and conversion; and the term domestic includes units within the fifty states, the District of Columbia, Puerto Rico, the Virgin Islands, Guam, and the Pacific Islands. This exception operates as the uppermost limit on all lending to one borrower. 77 Fed. Reg (June 21, 2012). 12 C.F.R. 32.3(d). 7. Calculating the Credit Exposure for Derivative Transactions. 12 C.F.R a. The credit exposure for a derivative transaction is commonly viewed as the sum of the current credit exposure on the control or portfolio plus some measure of potential future exposure (PFE). b. Credit exposure of derivative transactions other than credit derivatives. Unless required to use a specific method to determine credit exposure, by the appropriate Federal banking agency pursuant to 32.9(b)(3), a national bank or savings association may choose one of three methods to compute credit exposure. 12 C.F.R. 32.9(b)(1). A national bank or savings association must use the same method for all calculations.

13 Page 13 (1) The Internal Model Method estimates counterparty credit exposures via an internal model approved by the OCC that estimates a credit exposure amount, including the mark-to-market value (MTM) of the derivative contract. The model must have been approved for purposes of section 53 of the Advanced Approaches Appendices of the appropriate Federal banking agencies capital rules or be another appropriate model approved by the appropriate Federal banking agency. The bank or savings association is permitted to net credit exposures of derivative transactions arising under the same qualifying master netting agreement, thereby reducing the institution s exposure to the borrower to the net exposure under the master netting agreement. (2) Under the Conversion Factor Matrix Method, credit exposure equals and remains fixed at the PFE of the derivative transaction as determined at execution of the transaction by reference to a lookup table similar to Table B included in the Risk-Based Capital Guidelines Appendix of 12 C.F.R. Part 3. (a) (b) The table adequately reflects the absence of the current MTM component of the credit exposure of these transactions. This approach is less burdensome than the Internal Model Method because institutions do not have to establish statistical simulations of future PFE calculations. (3) The Remaining Maturity Method incorporates both the current MTM and the transaction s remaining maturity (measured in years) as well as a fixed add-on for each year of the transaction s remaining life. (a) (b) The additional burden involved with determining the MTM under this method may be balanced by the fact that, depending on the MTM, as the maturity decreases, the credit exposure also decreases, permitting additional extensions of credit under the lending limit. The Remaining Maturity Method incorporates the fact that a negative MTM offsets the positive contribution to exposure from the remaining life portion of the calculation, though the overall calculation has a floor of zero.

14 Page 14 c. Credit derivatives. A special rule applies to credit derivatives. A national bank or savings association that uses the Conversion Factor Matrix Method or Remaining Maturity Method, or that uses the Internal Model Method without entering an effective margining arrangement with its counterparty, calculates the counterparty credit exposure arising from credit derivatives by adding the net notional value of all protection purchased from the counterparty on each reference entity. 12 C.F.R. 32.9(b)(2). d. The OCC, in the case of national banks and federal savings associations, and the FDIC, in the case of state savings associations, may require use of a specific method to calculate credit exposure if it finds that such method is necessary to promote the safety and soundness of the bank or savings association. 12 C.F.R. 32.9(b)(3). 8. Calculating the Credit Exposure for Securities Financing Transactions. a. Banks and savings associations have two options for determining the credit exposure of securities financing transactions. 12 C.F.R. 32.9(c). b. The Internal Model Method provides that an institution may calculate the credit exposure of a securities financing transaction by using an internal model approved by the appropriate Federal banking agency for purposes of 32(d) of the Internal-Ratings-Based Appendices of the OCC or FDIC s capital rules, as appropriate, or any other appropriate model approved by the appropriate Federal banking agency. c. The Non-Model Method is based on the type of securities financing transaction at issue. This is considered to be a simpler approach. (1) Repurchase agreements and securities lending transactions. For a repurchase agreement or a securities loan where the collateral is cash, exposure is equal to and remains fixed at the net current exposure, i.e., the market value at execution of the transaction of securities transferred to the other party, less cash received from the other party. For securities lending transactions where the collateral is other securities (i.e., not cash), the exposure is equal to and remains fixed as the product of the higher of the two haircuts associated with the securities, as determined by a look-up table included in the regulation (Table 3), and the higher of the two par values of the securities. The haircuts in Table 3 are consistent with the standard supervisory market price volatility haircuts in 12 C.F.R. Part 3,

15 Page 15 Appendix C. 12 C.F.R. 32.9(c)(1)(ii)(B)(2). Reverse repurchase agreements (asset repos) and securities borrowing transactions. Where the collateral is cash, the credit exposure will equal and remain fixed as the product of the haircut associated with the collateral received, as determined in Table 3, and the amount of cash transferred to the other party. The credit exposure arising from a securities borrowed transaction where the collateral is other securities (i.e., not cash) shall equal and remain fixed as the product of the higher of the two haircuts associated with the securities, as determined in Table 3, and the higher of the two par values of the securities. 12 C.F.R. 32.9(c)(1)(ii)(C) and (c)(1)(ii)(d). d. The appropriate Federal banking agency may require a national bank or savings association to use a specific method to calculate the credit exposure of securities financing transactions if the agency finds that this method is necessary to promote the safety and soundness of the bank or savings association. 12 C.F.R. 32.9(c)(2). 9. Combining Loans to Separate Borrowers. Loans or extensions of credit to one borrower will be attributed to other persons and all will be deemed to be borrowers when the proceeds are used for the direct benefit of the other person(s) or when a common enterprise is deemed to exist between the persons. 12 C.F.R. 32.5(a). Loans to corporations, limited liability companies, partnerships, joint ventures, associations and foreign governments and their agencies will be attributed to their related entities under certain circumstances. See 12 C.F.R. 32.5(d)-(f). a. Direct Benefit. A loan to a borrower will be deemed to be for the direct benefit of another when the proceeds (or assets purchased with the proceeds) are transferred to the other person, other than in a bona fide arm s length transaction where proceeds are used to acquire property, goods, or services. 12 C.F.R. 32.5(b).

16 Page 16 b. Loans to a Common Enterprise. Loans to two or more persons will be attributed to each for the face amount of the loan when a common enterprise exists. 12 C.F.R. 32.5(c). The following circumstances each are deemed to constitute a common enterprise: (1) Where the expected source of repayment for each loan is the same and neither borrower has another source from which the loan, together with all other obligations of the borrower, may be fully repaid (subject to special rules for employer/employee situations); (2) Where the borrowers are related through common control, a common enterprise will exist if the persons also have substantial financial interdependence between them (when at least 50% or more of one person s gross receipts or expenditures are derived from transactions with the other borrower); (a) (b) Control exists when one or more persons has the power to vote at least 25% of any class of the voting securities of another; or Control exists when one or more persons has the power to elect a majority of the directors or to direct the policies and management of another, 12 C.F.R. 32.2(h); (3) Where separate persons borrow to acquire a business of which the persons will own more than 50% of the voting securities, the acquisition loans are combined and attributed to all; or (4) Where the appropriate Federal banking agency determines, based on the facts and circumstances, that a common enterprise exists. 12 C.F.R. 32.5(c)(1)-(4). c. Loans to Corporations and Limited Liability Companies. (1) Loans made pursuant to the general limitations in 12 U.S.C. 84(a)(1)-(2) to a corporate group (consisting of a person and all of its subsidiaries) cannot exceed 50% of capital and surplus. 12 C.F.R. 32.5(d)(1). Since this limitation applies only to loans made pursuant to 12 U.S.C. 84(a)(1)-(2), the limitation does not apply to a loan made, for example, under the general 35% limitation in 12 U.S.C. 84(c)(3) (loans secured 115% by bills of lading).

17 Page 17 (2) Loans to a person and its subsidiary or different subsidiaries will be attributed to each for the face amount of the loan when the direct benefit or common enterprise test is met. 12 C.F.R. 32.5(d)(2). (3) Subsidiaries of a person include: (a) (b) A corporation (or limited liability company) of which the person owns or beneficially owns, directly or indirectly, more than 50% of the voting stock; and A corporation (or limited liability company) owned indirectly so that if A owns more than 50% of Corporation X which itself owns more than 50% of Corporation Y, A s subsidiaries include both corporations. 12 C.F.R. 32.5(d)(1). d. Loans to Partnerships, Joint Ventures, Associations, and their Partners or Members. (1) Loans to a partnership, joint venture, or association ( partnership ) are considered to be loans to each partner or member ( member ), but are not considered to be loans to a limited member who is not liable for debts or actions of the partnership by the terms of the partnership agreement as long as those provisions are valid under applicable law. 12 C.F.R. 32.5(e)(1). (2) Loans to individual members (general or limited) of a partnership are attributed to the partnership only where the direct benefit or common enterprise test is met. Both tests are met where the loan is made to a person for the purpose of purchasing an interest in the partnership. Loans made to a member of a partnership will not be attributed to another member individually unless the direct benefit or common enterprise test is met. 12 C.F.R. 32.5(e)(2). e. Loans to Foreign Governments, their Agencies and Instrumentalities. Loans to foreign governments, their agencies and instrumentalities will be combined under 12 U.S.C. 84 only if they fail to meet either of the following tests at the time the loan is made:

18 Page 18 (1) Means Test. The borrower has its own resources sufficient over time to service its obligation, but if the government s support (excluding guarantees by a central government) exceeds the borrower s annual revenues from other sources then it is presumed that the means test has not been satisfied; or (2) Purpose Test. The purpose of the loan is consistent with the purposes of the borrower s general business. 12 C.F.R. 32.5(f)(1). The bank or savings association must maintain certain items in its files to show compliance with the means or purpose test. 12 C.F.R. 32.5(f)(2). f. Special rules apply to restructured loans. 12 C.F.R. 32.5(f)(3). 10. Nonconforming Loans. a. Defined. A loan, within lending limits when made, will not be deemed a violation but instead will be treated as nonconforming when: (1) The bank s or savings association s capital has declined, borrowers have merged or formed a common enterprise, lenders have merged, or capital rules have changed (referred to here as changed conditions ); (2) Collateral used to satisfy a higher lending limit allowance has declined in value (referred to here as decline in collateral ); or (3) In the case of a credit exposure arising from a transaction identified in 32.9(a) and measured by the Internal Model Method specified in 32.9(b)(1)(i) or 32.9(c)(1)(i), the credit exposure increases after execution of the transaction. 12 C.F.R. 32.6(a). b. Actions To Be Taken. (1) When the nonconformity is due to changed conditions, the bank or savings association must use reasonable efforts to bring the loan into conformity, unless to do so would be inconsistent with safe and sound banking practices. 12 C.F.R. 32.6(b).

19 Page 19 B. State-Chartered Banks. (2) When the nonconformity is due to a decline in collateral, the bank or savings association must bring the loan into conformity within 30 calendar days, unless judicial proceedings, regulatory actions or other extraordinary circumstances prevent the bank or savings association from taking action. 12 C.F.R. 32.6(c) 1. Definitions and General Rule. a. Commercial Bank. A commercial bank is an institution that is incorporated under Maryland law as a State bank or trust company. Md. Code Ann., Fin. Inst (f) [hereinafter FI]. b. Unimpaired Surplus. The unimpaired surplus of a commercial bank includes surplus, retained earnings, and 100% of the possible loan loss reserves. FI 3-601(k). c. General Rule. A commercial bank may follow Maryland law (described below) or the loan to one borrower limitations applicable to national banks (described above). Letter from Joseph R. Crouse, State of Maryland Banking Department (Jan. 26, 1983) (discussing lending limits applicable to state banks). 2. General Limitation on Loans. The total liability of any one person to a commercial bank for loans, including standby letters of credit, at any one time may not exceed: a. 10% of the bank s unimpaired capital and surplus; or b. 30% of the bank s unimpaired capital and surplus if: (1) The excess over ten percent is approved by a two-thirds vote of the directors; and (2) The loans are secured by currency or obligations of the United States or Maryland or any political subdivision. FI 3-601(c)(2).

20 Page Exceptions as to Loans. In addition to the general limitations on loans noted above, the total liabilities of any one person to a bank may not exceed: a. 25% of the bank s unimpaired capital and surplus for discounts of commercial paper issued in a commercial transaction and negotiated by the person who owns it, or for discounts of chattel paper, negotiated by the person who owns it; and b. 25% of the bank s unimpaired capital and surplus for obligations, drawn in good faith against existing values, which are secured by goods in the process of shipment or secured by goods which, when accepted, will be accompanied by documents of title. FI 3-601(d)-(e). 4. Maximum of All Liabilities. The total of all liabilities of any one person to a bank, including all liabilities outlined above, may not exceed 30% of the bank s unimpaired capital and surplus. FI 3-601(b). 5. Computation of Total Liabilities. a. As to Individuals. Subject to subsection (3), below, the total liabilities of an individual to a bank include: (1) All liabilities of any partnership or unincorporated association of which the individual is a member; and (2) All loans made for the benefit of the individual or for the benefit of any partnership or unincorporated association of which the individual is a member. FI 3-601(g). (3) When the individual holds only a limited interest in a limited partnership, the individual s total liabilities for limited partnership liabilities may not exceed the value of the individual s interest in the limited partnership. Id. b. As to Partnerships and Associations. The total liabilities of a partnership or association to a bank include: (1) All liabilities of its individual members; and

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