I agree with doodles but want to take it one step further. In PA, you are allowed to choose which rules your are operating under for your loans. For instance, if you are a chartered savings bank like us, you could choose to operate under 7 PS 300 et seq rather than 7 P.S. 500 et seq. or under OTS' regulations. I was informed that if you were going to operate under something other than your chartered rules, your selected rule had to be consistently applied to a particular portfolio such as residential mortgage loans. My info was obtained from the PA Department of Banking - the horses mouth. Of course, check with your attorney before deciding.
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