Dimension 6 - Repayment Sources, Structure, & Documentation Flashcards
1
Q
Covenant Default
A
Failing to give notice to your customer of a covenant default may make your institution’s
future enforcement of the covenant difficult.
2
Q
Types of Loans
A
- Seasonal Line of Credit
- RLC
- Term Loans
- Leases
- Bridge Loans
- Mortgage Financing
- Special Programs
3
Q
Seasonal Line of Credit
A
- Short-term loan, usually less than one year, used to finance inventory and/or accounts receivable for a company with a seasonal financing need.
- Purpose: To finance the cash cycle
- May be secured by a perfected security interest in accounts receivable and inventory, at a minimum, and plant and equipment, at a maximum.
Sources of payment: • Contraction of current assets, specifically accounts receivable and inventory. • Conversion to long-term debt. • Liquidation of assets. • Additional equity.
4
Q
Three types of lines of credit
A
1) Unadvised Credit Line or Guidance Line - created when you obtain approval for a loan amount greater than the amount requested because you anticipate that the client will have a financial need in the near future. No “commitment” or “terms and conditions” letter is sent to the customer.
2) Discretionary Lines of Credit
- Expresses your intention to extend credit as required by the borrower at your sole discretion.
- Has the widest latitude in adjusting or terminating the line.
- The written agreement must make it clear that you have no legal obligation to honor a request made by the borrower.
3) Committed Line of Credit - evidenced by a written agreement signed by you and the borrower in which you commit to advance funds on specific terms at their request.
5
Q
Revolving Lines of Credit
A
- contractual agreement whereby the bank agrees to make loans up to a specified maximum for a specified period, usually a year or more.
- credit with advance rates and liens on current assets are also referred to as Asset-Based Financing in some banks.
- Purpose: to finance permanent working capital needs
- may be secured by a perfected security interest in accounts receivable and inventory, at a minimum, and plant and equipment, at a maximum. This
Sources of payment:
- Earnings and effective conversion and/or contraction of working capital.
- Conversion to term debt.
- Additional equity.
- Liquidation of assets
6
Q
Term Loans
A
- Structured as intermediate to long-term facilities, usually two to ten years.
- To finance the long-term needs of the company, including acquisitions, purchase of equipment or fixed assets
- First lien on fixed assets or a first or second lien on current assets
Sources of payment:
- Operating cash flows
- Liquidation of assets.
- Additional equity.
7
Q
Leases
A
- Contract granting the use of real estate, equipment or other fixed assets for a specified time in exchange for payment.
8
Q
Forms of leases
A
1) Financial or Capital Lease - The service provided by the lessor to the lessee is limited to the financing of the equipment.The lessee acquires essentially all of the economic benefits and risks of the leased property. The lease must be reflected on the company’s balance sheet as an asset with corresponding liability.
2) Operating Lease - Generally involving equipment, this contract is written for considerably less than the life of the equipment and the lessor handles all maintenance and servicing. Form of financing does not appear on the balance sheet of the lessee, but is a contingent liability
3) Sale and Leaseback - company sells an asset to another party in exchange for cash, then contracts to lease the asset for a specified term.
9
Q
Bridge Loans
A
- Short-term loan, also called a swing loan, made in anticipation of intermediate-term or long-term financing
Loan Purpose: Acquisition, Construction Projects
Sources of payment: Asset sale or refinancing through debt or equity
10
Q
Mortgage Financing
A
- Long-term loan that provides the lender with a lien on property as security for the repayment of the loan.
- For property such as machines, equipment, or tools, the lien is called a chattel mortgage.
- Sources of payment:
a) Cash Flow for property of a business or owner-occupied real estate,
b) Cash flow provided by the tenant leases will be key to repayment for investment property
11
Q
Industrial Revenue Bond Financing
A
- Involves the issuance of tax-exempt bonds by a public entity (ie. city)
• To finance the acquisition, construction, rehabilitation, improvement, equipping, and/or furnishing of facilities for qualifying companies
• To refinance outstanding tax-exempt bonds
12
Q
Subordinated Debt
A
- Usually placed for a longer-term (7-12 years) than senior debt and interest is payable at a fixed rate.
- sometimes referred to as mezzanine debt if there are equity warrants or convertible features attached to the subordinated debt.
- Sometimes referred to as mezzanine debt if there are equity warrants or convertible features attached to the subordinated debt.
- Sources of payment:
Cash Flow
13
Q
Private Placements
A
- Sale of debt or equity to a private or institutional investor, including individuals, insurance companies, pension funds, and investment companies.
- The placement agent (investment banker) plays an important role in explaining the company’s strategy to investors.
- Sources of payment:
Cash Flow
14
Q
Loan Syndications
A
- ## Credit facility that is originated by one or more lead banks acting as agents and sold to a group of financial institutions as participants.
15
Q
Loan Syndications
A
- Credit facility that is originated by one or more lead banks acting as agents and sold to a group of financial institutions as participants.
The following structuring options are typical: • Secured revolving lines of credit or term loans • Floating rates • 7-8 year terms • Varying amortization schedules Facilities can be structured as: • Revolving or term senior • Preferred stock • Private equity • Subordinated debt
- bank can participate in a syndicated loan either as a participant or an assignee.
16
Q
Difference between participant and assignee in Syndications?
A
Participants purchase shares in the transaction, but do not have a contractual relationship with the borrower.
Assignees purchase shares in the transaction after the closing and do become party to the credit agreement.
17
Q
High Yield Debt
A
Involves underwriting public debt issues for non-investment grade companies.
Typical buyers of this debt are mutual funds, insurance companies, pension funds, and individual investors.
18
Q
Commercial Paper
A
- financing vehicle for companies with investment grade credit ratings (AAA to BBB) that need low-cost, short-term, unsecured financing.
- Corporations issue commercial paper directly to investors who may have temporary idle cash to invest.
- unsecured and generally discounted
- provides short-term working capital funding with flexible maturities and lower rates (than bank funding) for investment grade corporations
19
Q
Letters of Credit
A
- An instrument issued by a bank on behalf of its customer that gives someone (beneficiary) the right to draw funds upon the presentation of papers or documents in accordance with its stipulated terms and conditions.
20
Q
Documentary L/Cs
A
- Typically used in international trade where the customer is not well known or the customer’s credit is suspect.
- The L/C essentially substitutes the issuing bank’s credit for that of the importer.
21
Q
Standby L/Cs
A
- issued in lieu of a guarantee and protect the beneficiary financially in the event the bank’s customer defaults.
- used in commercial transactions, as enhancements in municipal bond transactions, and to guarantee performance on construction contracts.
22
Q
Banker’s Acceptance
A
- a time draft (signed, written order by which one party instructs another party to pay a specified sum to a third party on a certain date) drawn on and accepted by a bank. It is the customary means of effecting payment for merchandise sold in import-export transactions and a source of financing used in international trade.
- primarily used to finance international trade.
23
Q
Asset Securitization
A
pooling homogeneous groups of assets, such as credit card receivables, mortgages, corporate accounts receivable, auto, or consumer loans and financing them with securities (credit instrument that signifies ownership) that are sold to investors.
24
Q
When is a Guarantee Required?
A
- The borrower’s form of organization influences whether a guarantee may be needed.
- Generally, for privately held borrowers a guarantee is highly desirable whenever the form of organization does not already incorporate personal liability (i.e. the borrower is not a proprietorship or a general partnership). In addition, guarantees are highly recommended when there are multiple legal entities sharing the same ownership, and when it is possible for the borrower’s financial resources to be easily redistributed within those entities.
25
Corporation - Guarantee
- most lenders require that a corporation’s major stockholders guarantee a loan to a closely held corporation.
- Sometimes, a corporation may be asked to guarantee the debt of another entity.
- The shareholders, directors, officers and employees are not otherwise liable for corporate debt.
26
Limited Liability Company - Guarantee
- most lenders also require that a limited liability company’s members guarantee a loan to the limited liability company.
- members have no individual liability for the debts of the company
27
Limited Partnership and General Partnership - Guarantee
- General partners may be required to guarantee a partnership debt, even though the general partners are legally liable for partnership debt. The guarantee agreement allows you to act sooner.
28
Limited Liability Partnership and Limited Liability Limited Partnership - Guarantee
- Most banks’ loan policies require that partners in the limited liability partnership guarantee a loan to the partnership and that the general partners in a limited liability limited partnership guarantee a loan to the partnership.
- partners have no individual liability for partnership debts incurred by the partnership after registration as a limited liability partnership or limited liability limited partnership.
29
Spouses - Guarantee
- Spouses of the original borrower and guarantors should be required to execute a guarantee in community property states.
- In community property states, if an applicant requests unsecured credit, federal law permits requests for a guarantee from a spouse.
- In non-community property states, federal law prohibits requests for a guarantee from a spouse. A lender may request “more creditworthy co-guarantors” and may accept guarantees of spouses if the guarantors volunteer them.
30
Collection from a Guarantor in Event of Default
Most states provide guarantors with legal defenses and claims against the lender that can make collection difficult. Your position is strengthened if you obtain evidence that the guarantor understands the terms of the loan.
You should not make subsequent changes to the loan without a written statement of understanding and consent by the guarantor, as well as a written confirmation that the guarantee is not affected by the change. You should also notify the guarantor of any defaults that occur in the underlying credit transaction.
A guarantee, by its terms, can be revoked at any time but only as to debt incurred after the revocation.
31
Special Consideration for Enforcing Small Business Association (SBA) Guarantees
* Did you close the loan in accordance with the SBA authorization letter, as appropriately amended?
* Did you comply with the monitoring and credit management requirements of the authorization?
* Did you act with normal prudence for the industry and comply with the rules and regulations of the SBA in managing the liquidation?
32
Comfort Letters
- letters issued to lenders by companies to indicate support for another entity borrowing from the lender.
- most often issued by parent companies in connection with subsidiary borrowings.
- generally fall short of an absolute promise to pay the borrowing entity’s debt.
- companies that favor comfort letters are generally public companies that do not want to have to include contingent liabilities in their financials.
- Comfort letters are enforceable.
33
Loan Covenants
- designed to protect the bank
- should identify key risk points in the company’s operating profile
- identify the specific risks against which the bank needs to be protected and to prevent certain actions by the company that could jeopardize the timely repayment of the loan.
- should be those that the bank expects to enforce-
- Covenants provide timely warning signs.
Covenants bring the borrower back to the table.
34
Covenant Objectives
* Full Disclosure of Information
* Protection of Net Worth
* Protection of Cash Flow
* Protection of Asset Quality
* Control Growth
* Maintenance of Key Management
* Assurance of Legitimacy and the Company as a Going Concern
* Profitability for the Bank
35
Sole Proprietor
- an individual operating as a business. There is no separate business entity, only the individual operating the business.
- personally liable for all debts of the business.
- If the borrower is doing business under an assumed name (also known as a d/b/a, a tradename, or fictitious name), obtain a copy of the assumed name filing permitted
- An individual "doing business as" (d/b/a) another name should sign his or her correct legal name with the d/b/a noted only if required elsewhere in the loan documents--not in or above the signature line. The d/b/a should be noted in the loan documents only if requested by the customer.
36
General Partnership
- business operated by two or more general partners.
- individual partners are liable for the partnership debts, and their personal assets are exposed to liability for the debts.
Identification needed: Obtain the agreement from the partnership. If there is no formal written
agreement, obtain a written statement that none exists.
Authorization: obtain a partnership resolution to borrow, guaranty or grant collateral interests,
37
Limited Liability Partnership
- The partners in a limited liability partnership are not liable for the debts of the partnership unless the debts existed prior to the election to become a limited liability partnership or they have guaranteed the debts.
- Identification Needed: Partnership agreement, Partnership certificate, Proof of registration for Limited Liability Partnership status
- Authorization: partnership resolution to borrow, guaranty or grant collateral interests
38
Limited Partnership
- made up of one or more general partners and one or more limited partners. MUST have at least one general partner
- purpose of a limited partnership is to allow one or more individuals to provide capital without having to assume liability for debts.
- Limited partners are not liable for the debts of the partnership unless they have guaranteed the debts.
- only lose the amount of their investment in the partnership.
- General partners control the activities of the business and have full liability.
- Identification Needed: Limited Partnership Agreement
- Authorization: partnership resolution to borrow, guaranty or grant collateral interests
39
Limited Liability Limited Partnership
- The limited partners are not liable for the debts of the partnership unless they have guaranteed the debts.
- General partners are not liable for the debts of the partnership unless the debts existed prior to the
election to become a limited liability limited partnership or they have guaranteed the debts.
- Identification Needed: Limited Partnership Agreement
- Authorization: partnership resolution to borrow, guaranty or grant collateral interests
40
Joint Venture
- one-time partnership for a specific purpose
- The participants in a joint venture are not individually liable for unpaid debts of the joint venture unless they have guaranteed the debts.
41
Corporation
- exists independently and apart from the people who own it.
- shareholders are liable only to the extent of their investment in the corporation.
- shareholders, officers and directors are not personally liable for unpaid debts of the corporation unless they have guaranteed the debts.
- Identification Needed:
a) Articles of Incorporation - prove the existence of the corporation.
b) Bylaws and any amendments.
c) Corporate Certificate of Good Standing from the state.
- Authorization: corporate resolution signed by the Corporate Secretary. If the Secretary is authorized to borrow on his or her signature alone, the certificate should also be signed by an officer other than the Secretary
42
Limited Liability Company
- consists of Members, who own the limited liability company and select a manager.
- The manager, who may or may not be a member of the limited liability company, operates the company on a day-to-day basis and is removable at the will of the members.
- members are liable only to the extent of their investment in the limited liability company.
- members are not individually liable unless they have guaranteed the debts.
- Identification Needed:
a) Articles of Organization
b) Operating Agreement- provides the rules under which the liability will function and designates a managing member or members.
c) Limited Liability Company Certificate of Good Standing.
Authorization: Limited Liability Company resolution- this is the document by which the members of the company grant authority for persons to make agreements and sign documents on behalf of the company.
43
Nonprofit Corporation
- a public or quasi-public entity established for administration of public affairs or for charitable, religious, or benevolent purposes.
- Identification Needed: Charter of Association, Bylaws and any amendments, Association Certificate of Good Standing from the state.
- Authorization: resolution signed by the corporation Secretary
44
Trust
- obligation of special trust to another entity
- The trustee is not liable for the unpaid debts of the trust unless the trustee has guaranteed the debts.
- Identification Needed/Authorizaton: Trust Agreement
45
Estate and Guardianship
- have an obligation of special trust to other persons.
- They come into existence when a person dies or is subject to guardianship proceedings
- Identification Needed/Authorization: certified copy of court order appointing administrator/executor/ personal representative/guardian.
46
What's the major cause for lender loss on commercial loans?
Documentation errors
47
Proposal Letter/Term Sheet
- A clear listing of all information you will require the potential borrower to deliver to you before further considering a possible loan transaction.
- summary of the significant terms
- statement that the terms included are not the only terms that you may require.
- statement that you will require additional documentation to close the loan.
- clear statement that you are not making a commitment to lend.
- An expiration date for the proposal
48
Commitment Letter
- clear listing of all information you will require the potential borrower to deliver to you before the loan closing.
- summary of the significant terms you will require
- a statement that the terms included are not the only terms that you may require.
- a statement that you will require additional documentation to close the loan.
- a clear statement that the commitment is a nonassignable
- an expiration date for the commitment.
49
Promissory Notes
A promissory note is a written promise by one person to pay money to another. The person
making the promise is called the maker of the note. The person to whom payment is made is
called the payee.
50
Types of Loans
1) Demand: A demand loan is payable by the borrower whenever you make demand for payment. A promissory note may be made payable upon "the earlier of demand or" a specified date or by a specified installment schedule.
2) Time loan: In a time loan transaction, the payee extends credit to the maker for a period of time until the payment is due. It may be payable in a single payment or in installment payments. Once any part of the loan is repaid, the amount cannot be re-borrowed. If the time is longer than one year, the loan is a term loan.
3) Revolving credit: In a revolving credit transaction, the borrower is permitted to borrow all or part of the principal amount, repay it all at once or in part, and re-borrow it up to the committed amount. The note may have a demand feature making it payable in full on demand or at a specific date.
4) Nonrevolving multiple advance loan: In a nonrevolving multiple advance loan transaction, the borrower is permitted to borrow all or part of the principal amount. Amounts borrowed and repaid cannot be borrowed again.
51
Content of Loan Agreements
```
Terms and conditions
Representations and Warranties
Affirmative and negative covenants
Conditions of Lending ie. Delivery of required financial statements.
Events of Default
Remedies
Miscellaneous
```
52
Security Document
- an agreement that creates or provides for a security interest in assets of the borrower or some third party to secure repayment of a loan(s).
- It is an agreement between two parties, the grantor of the security interest (the Debtor) and the lender (the Secured Party).
- security agreement must reasonably identify the collateral.
53
Mortgages/Deeds of Trust
- A mortgage is an agreement between two parties, a mortgagor and a mortgagee. The mortgagor is the party granting the lender an interest in real property to secure repayment of a loan. The mortgagee is your institution.
- A deed of trust is an agreement among three parties, a trustor, a trustee and a beneficiary. The trustor is the party granting an interest in real property to secure repayment of a loan.
54
Three types of lines of credit
1) Unadvised credit lines
2) Discretionary Lines of Credit
3) Committed Line of Credit
55
Unadvised Lines of Credit/Guidance Lines
- You may obtain approval for a loan amount greater than the amount requested by a borrower because you anticipate that a customer will have a future financial need
- No "commitment" or "terms and conditions" letter is sent to the customer.
56
Discretionary Lines of Credit
- Established for a specified period of time and expresses your intention to extend credit as required by the borrower but at your sole discretion.
- It is intended to provide you with the widest latitude in adjusting or terminating the line of credit.
- no legal obligation to honor a request made by the borrower
57
Committed Line of Credit
- arrangement evidenced by a written agreement signed by you and the borrower in which you commit to advance funds on specific terms at their request.
58
Participation Agreements
- written agreement between two or more lenders for the purchase by one or more lenders of an interest in a loan or loans originated by another.
- A more complex type of participation arrangement is that which is often referred to as a loan syndication.
59
UCC provides that a security interest attaches to collateral when three conditions have been met.
1) The debtor or third party grantor must sign a security agreement. You may also take possession of the collateral.
2) The debtor or third party grantor must have "rights" in the collateral.
3) The lender must give "value" for the collateral. Value given means that the lender makes the loan, issues a letter of credit, or makes credit available whether or not it is drawn upon. A lender also gives value when it has a right to call a loan and foregoes that right in exchange for a new security interest.
60
Methods of Perfection
1) Perfection by Possession (Possessory Liens)
2) Perfection by Filing (UCC Filings):
3) Perfection by Compliance with Other Statutes
4) Temporary Perfection
61
Rules for Establishing Priority Between Two Secured Parties
The UCC sets forth complex rules for establishing priorities for many different applications. The rule most applicable for documentation purposes is the one that governs conflicting security interests in the same collateral. In general, in these situations "The First to File or Perfect" rule applies.
62
Improving Priority Position
- attempt to obtain a waiver or a subordination of the other creditor's rights.
63
Purchase Money Security Interests
- exists when the proceeds of the secured loan are used to acquire the collateral.
- You must perfect the purchase money security interest by filing a UCC-1 financing statement no later than 20 days after the debtor receives possession of the collateral.
64
Landlord Waivers
- In some states, a landlord has an automatic lien for unpaid rents against the property of the tenant
- The landlord's lien may have precedence over a previously granted security interest.
- You should obtain a waiver, disclaimer or subordination of the interest of the landlord in the property of the tenant to permit repossession of the collateral in the event of default.
65
Types of Possesion - Perfection
1) Actual Possession
2) Constructive Possession: Brokerage/Trust = Accountsa third party holds the collateral in an account owned by the borrower.
3) Time of Perfection by Possession
66
UCC Filings - Documentation Requirements
Security Agreement
Financing Statement - The purpose of filing a financing statement is to give public notice to other creditors that you claim an interest in the collateral.
67
UCC Notes
- You may amend an existing financing statement by filing a UCC-3.
- A financing statement generally is effective for five years.
- To continue perfection beyond five years, a continuation statement (usually designated a UCC-3) must be filed.
- A debtor must receive a termination statement within 10 days of its request if the debt has been fully paid and no future advances are anticipated.
- Except for filings covering timber, minerals and fixtures, a filing is effective only if it is made in the designated central location in the state where the debtor is located.
* The “debtor is located” in the state where it was formed as an entity if registration was required.
* If registration was not required, the “debtor is located” in the state where the debtor resides if an individual or has its place of business if not an individual.
* If registration is not required and the debtor has more than one place of business, the “debtor is located” in the state where its chief executive office is located.
68
Types of ownership
```
Fee Simple Estate
Life Estate
Leasehold Estate
Tenancy by the Entireties
Joint Tenancy
Tenancy in Common
Homestead
```
69
Fee Simple Estate
the owner(s) is entitled to the entire property, with unconditional power of disposition during the life or existence of that owner(s).
70
Life Estate
The duration of a life estate is limited to the life of the party holding it, or the life of some other person. The estate ends when the life of the person ends.
71
Leasehold Estate
A leasehold estate is an estate held under a lease for a fixed term. The estate ends when the lease terminates.
72
Joint Tenancy
A joint tenancy involves ownership of real property by two or more persons. If the joint tenancy includes rights of survivorship, title passes to the surviving owner(s) . If the joint tenancy is without rights of survivorship title of the deceased owner passes to the heir(s) of the deceased owner if one of the owners dies.
73
Tenancy in Common
A tenancy in common involves ownership of real property by two or more persons. A tenancy in common is always inheritable. If one of the owners dies, the ownership share of that deceased owner passes to the heir(s) of the deceased owner.
74
Homestead
artificial estate in land devised to protect the possession and enjoyment of the owners against the claim of creditors.
75
Title Insurance Policy Notes
- title insurance binder is not a final title insurance policy.
- It is an agreement to issue a final title insurance policy in accordance with the terms of the binder if the conditions contained in the binder are met.
- Your institution should be named as the insured party on the final title policy.
76
What are the most reliable methods for determining the value of real property collateral
Evaluations and Appraisals
Note: Federal law requires an appraisal by a state-licensed appraiser whenever the lender makes a loan in the amount of $250,000 or more secured by real property. For loans under $250,000, the lender may accept an evaluation of the property
77
What are factors that could have a negative impact on the value of real property collateral?
Environmental Hazards
Easement Problems
Encroachment Problems:
78
Insurance Notes
Bank should be named as a loss payee
79
Collateral Agreements
A third-party security agreement (sometimes called a hypothecation agreement), mortgage or deed of trust is an agreement by someone other than the borrower or guarantor to provide the collateral for the loan.
80
Comfort Letters
- letters issued to lenders by companies to indicate support for another entity borrowing from the lender.
- often issued by parent companies in connection with subsidiary borrowings.
- comfort letters are generally public companies that do not want to have to include contingent liabilities in their financials.
- Comfort letters are enforceable.
81
Phase I
Warranted whenever there is reason to suspect contamination
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Phase II
Warranted whenever the Phase I assessment indicates evidence of contamination. In this phase, soil and groundwater samples are taken and tested to determine the actual extent of contamination, if any.
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Phase III
Consists of remediation procedures for contamination discovered and confirmed in Phases I and II. The Phase III audit report spells out the full extent of the contamination, what the mitigation procedures must be, and the costs expected to be incurred in the cleanup.
84
REGULATION B (EQUAL CREDIT OPPORTUNITY ACT)
- prohibits discrimination based on race, color, religion, sex, marital status, national origin, age (if an adult), receipt of income from a public assistance program, or the good faith exercise of any rights granted under the Consumer Credit Protection Act.
- Reg B Violation: Requests for a spousal guaranty in a community property state, when the applicant has sufficient separate property to qualify for the loan requested.
85
REGULATION U (STOCK-SECURED LOANS)
- intended to protect the national economy and individual investors by preventing excessive speculation on credit in the stock market. It limits the credit any bank may extend when margin stock is used as security for the purpose of purchasing additional margin stock. This type of loan is called a regulated loan.
86
REGULATION O (FINANCIAL INSTITUTIONS REGULATORY REFORM AND INTEREST-RATE CONTROL ACT (FIRA)
- pertains to insider loans
- prohibit extending credit to
insiders or their related interests unless it is on substantially the same terms as those
prevailing at the time for comparable transactions with other persons and does not involve
more than normal risk of nonpayment.
87
Holding Company Lending
Lend to a holding company with an upstream guarantee from the operating subsidiaries secured by a pledge of assets.
88
What are key risks in lending to holding companies?
Current or future creditors will have a priority claim on the assets or cash flows of the company.
89
What are key covenants when lending to a holding company?
– No additional debt at any level of the corporate structure.
– No pledge of assets at any level of the corporate structure.
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Contract Elements – requirements to make an agreement enforceable
- Legal Purpose
- Legal Capacity
- Consideration
- Mutual Assent (Meeting of the
Minds)
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The Community Reinvestment Act
intended to encourage depository institutions to help meet the credit needs of the communities in which they operate, including low- and moderate-income neighborhoods
