Interagency Q&A .12(n) – 3: Do “niche institutions” qualify as limited purpose (or wholesale) institutions?

Compliance > Regulation BB - CRA
Q:  § __.12(n) – 3: Do “niche institutions” qualify as limited purpose (or wholesale) institutions?
 
A:  Generally, no.  Institutions that are in the business of lending to the public, but specialize in certain types of retail loans (for example, home mortgage or small business loans) to certain types of borrowers (for example, to high-end income level customers or to corporations or partnerships of licensed professional practitioners) (“niche institutions”) generally would not qualify as limited purpose (or wholesale) institutions.
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 

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