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Banking Interpretations

GRBB Part77

April 21, 2005 11:00 AM

Steven Barras/legal/NYSBD

To [ ]

cc Sara Kelsey/legal/NYSBD@NYSBD,
Thomas Weisfeld/exmnr/NYSBD@NYSBD,
Cheryl Lewis/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.

Steven Barras
First Assistant Counsel