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Small Creditor Status If Branches In Rural County

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Question: 
Main bank and two branches are in rural/underserved counties. One branch is in an MSA. Will this affect our Small creditor status?
Answer: 

Small credit status is determined by where you make your loans and not where your branches are located:

“During the preceding calendar year, the creditor extended over 50 percent of its total first-lien covered transactions, as defined in § 1026.43(b)(1), on properties that are located in counties that are designated either ‘rural’ or ‘underserved,’...”

[Editor's note: Beginning January 1, 2014, that provision is amended to read “During any of the three preceding calendar years,....”]

First published on 12/16/2013

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