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#379565 - 06/30/05 06:23 PM COMMERCIAL LOC
michellecc Offline
100 Club
michellecc
Joined: Sep 2003
Posts: 128
Southern New England
Hello. Are there any compliance issues w/ paying a commercial LOC payment from the LOC itself? Thanks.

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#379566 - 06/30/05 07:12 PM Re: COMMERCIAL LOC
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I can only suggest that a pattern of allowing such transactions might be considered an unsafe or unsound banking practice, and recurring use ought to cause the lender to scrutinize the borrower for potential loan classification.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#379567 - 07/01/05 07:07 PM Re: COMMERCIAL LOC
etm614 Offline
Platinum Poster
etm614
Joined: Jan 2003
Posts: 695
Massachusetts
This really isn't a compliance issue but a credit risk issue. As a former examiner, I participated on an exam of a bank that allowed this practice - the bank was closed within a month of the completion of the exam. If the LOC payments can only be made from the line itself due to a well-defined and limited seasonal need (followed by a true repayment period), then the structure of the credit is incorrect. Otherwise, I can think of no reason to allow this practice.

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