What if I have a loan secured by commercial real estate that is not considered a “CRE” loan for purposes of the CRE Concentration Guidance?
A. Eligibility is not tied to whether a loan fits within the parameters of a “CRE” loan as that term is used in the Concentration Guidance. Thus, for instance, loans secured by agricultural land should be eligible. However, ultimate decisions about which loans will be accepted into the LLP will be made by the bank’s primary regulator, Treasury, and the FDIC.