Hi all, I'm rather new to being at a State Bank, my experience is with a National Bank. When determining guidelines for lending, does the PA Dept of Banking Code supercede FDIC regulations?

Specifically, we have a request for a seven-year commercial term loan secured by unimproved land. The FDIC regs do not have any specific guidelines regarding terms for commercial loans. However, the PA Dept of Banking Code in section 310 (a) (ii) states that in the case of unimproved land, the term is not to exceed five years.

You will have to comply with state law.

You should take a look at the Department of Banking website to check out the Letter from 11/14/2012 about the Banking Law Modernization Package which basically rewrote the PA Banking Code and eliminated Section 310 among others. The Modernization Package eliminates many archaic lending laws.
http://www.portal.state.pa.us/portal/ser...ion_package_pdf

If you have the PA Banking Code printed out you will want to replace it with the new version available on the website. Much simpler.

Didn't they even do away with usury limits?

could someone provide the link to the new version of the PA Banking Code. I have looked on the website and can not find it. thank you!

It states in the link above under a summary of changes that "PA state-chartered banks and savings banks are no longer subject to any interest rate or fee restrictions in their lending activity."

Thanks doodles. I specifically asked a person from the PA Dept of Banking about amendments to the 1965 Code, and he didn't mention this letter.