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Robert, Our counsel has advised that we should not have to worry about the rule applying to collateral review (such as FHLB), or any other internal or external required loan review (audits and exams), as those are things we are subject to under ...

Another consideration is pledging loans as collateral to FHLB and/or FRB for liquidity management purposes.  Given that the notes serve as underlying collateral to the agencies, and the agencies do perform periodic reviews of the collateral quality, these ...

On a single tenant building, I would perhaps consider a vacancy factor based on potential vacancy over an extended period of time, but then annualize it.  I believe this is the practice employed by appraisers and investors.  For instance, over a 5 year ...