April 21, 2005 11:00 AM
To [ ]
cc Sara Kelsey/legal/NYSBD@NYSBD,
Subject Commercial Loan Portfolio
In your E-Mail of March 8, 2005 to Assistant Deputy Weisfeld, you asked whether there are any limitations on the size of a savings bank's commercial loan portfolio. There is no New York law or regulation that limits the size of a savings bank's commercial loan portfolio. Section 103(1) of the New York Banking Law and Part 77 of the Banking Board's General Regulations only limit the amount of loans to any one borrower. Consequently, there is nothing analogous to the "Qualified Thrift Lender Test" that is set forth in Federal Law. The size of a commercial loan portfolio would only be limited, in a particular case, as a matter of supervisory policy.
First Assistant Counsel