Re: combo loans


Both Deborah, who I hired into her current position many years ago, and your supervisor have valid points. Deborah’s analysis relies on a strict reading of the definition. Your supervisor appears to be looking at the substance of the transaction. Unfortunately my opinion, Deborah’s opinion and your supervisor’s opinion do not count. The issue is not addressed in Regulation C, the official staff commentary or the FAQs. You should run this by your examiner to find out how he/she wants it reported.