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#501628 - 02/21/06 07:54 PM Lending Test???
Bullseye Offline
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Bullseye
Joined: Jan 2004
Posts: 968
I am reading a PE from another bank who received credit under their lending test for contributions to a downpayment assistance program. I am confused. I would think that would fall under the investment test. Can anyone explain this to me?

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CRA
#501629 - 02/22/06 12:38 PM Re: Lending Test???
AnonRegulator Offline
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AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
If the bank donated money to this program, i.e., grants, then you are correct that this probably should have been addressed in the investment test. However, sometimes when we try to describe a particular program in a PE, the program may have features that fit more than one test. Rather than discuss the same program repetitively in the PE (and PEs in general are just too long), we may just discuss it once, putting it in the section that seems to fit the best. Without knowing the specific PE, perhaps that is what happened in your example. AR.

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