The four federal depository institution regulatory agencies have received more than 940 comment letters on their proposals to set loan-to value ratios for real estate lending by thrifts and banks. these are excerpts from comments by the American Bankers Association to the Federal Reserve Board (see The Mortgage Marketplace. Sept. 7. page 1).

If the Board decides to adopt the regulatory estab"shed LTV ratios in conformance with the proposed rule. then the ABA recommends adoption of Alternative One with significant modifications. This alternative establishes ranges of individual lender LTV ratio standards that allow limited fiexibility for financial institutions in the selection of an appropriate level for each category of real estate loan within the range. Alternative Two establishes uniform maximum LTV ratio standards applicable for all financial institutions regardless of any other aspect of the institution's market or operation. On the whole. use of a range. rather than a national. uniform standard. recognizes the differences in regional needs and prudent practices. as well as financial institution expertise in lending and service to customers.

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