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However, the lender may use their in house credit guidelines on collateral policy for loans greater than $25,000 up to $350,000.
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may not really want to make the loan, and ‘Oh, our regulator won’t let me do that. ’ So some of that happens. ”Regulators at the forum emphasized the need to balance the regulatory process to ensure that prudent loans are made, while minimizing the potential for examiner or banker overreaction. They acknowledged that instances of conflicting messages should be minimized and discussed the process for consistently communicating policies from Washington, DC, to field examiners. They also indicated that feedback mechanisms are available for bankers to voice concerns about examiner application of policies through agency management chains and ombudsmen. For example, Federal Reserve Chairman Bernanke noted, “he Federal Reserve’s had an ombudsman since 1995…f you’re a bank and you think you’re not getting fair treatment and you’re worried for some reason about complaining to your examiner, then call Washington and we’ll respond to that. ” Similarly, FDIC Chairman Bair stated, “f you have a situation where you don’t think that policy has been applied, I want to know about it, because we’re really trying very hard not just to articulate these policies in Washington, to make sure they are followed in the field. ” Forum participants also called attention to the FDIC Small Business Hotline, a new tool that allows borrowers with an inquiry or comment about small business lending to contact the FDIC directly. 6 FDIC Chairman Bair said the hotline will help regulators assist small business borrowers and learn more about banks’ lending practices: “Not only do we want to help these borrowers, but also we can track this information the way track consumer inquiries. And if the particular banks areas where we’re seeing…a greater frequency of problems, we can look at that more deeply. So I think it will be very helpful to us as a supervisory tool as well.