Third Appraiser has the meaning set forth in Section 6.04(b) hereof. Regardless of how entrepreneurial profit is handled in the appraisal analysis, an appropriate explanation and discussion should be provided in the appraisal report. To implement these provisions, the Agencies recognize that future regulations will address the requirement that the appraiser conduct a physical property visit of the interior of the mortgaged property. In response to commenters, the Guidelines now provide examples of factors for an institution to consider in assessing whether a significant change in market conditions has occurred. Exposure TimeAs defined in USPAP, the estimated length of time the property interest being appraised would have been offered on the market prior to the hypothetical consummation of a sale at market value on the effective date of the appraisal. The institution should employ audit procedures and review a representative sample of appraisals supporting pooled loans or real estate notes to determine that the conditions of the exemption have been satisfied. Evaluation Development and Evaluation Content. FIRREA allows an exemption from a state licensed or state certified appraisal for business loans of $1M or less that are not dependent upon the sale of, or rental income generated from the collateral real estate as the primary source of repayment. A "business loan" is defined as an extension of credit to "any" corporation or other business entity. For residential transactions, loan production staff can use a revolving, pre-approved appraiser list, provided the development and maintenance of the list is not under their control. As specified in the Agencies' appraisal regulations, an institution must obtain an evaluation of the real property collateral, if no other appraisal exemption applies. Abolishment of the Federal Savings and Loan Insurance Corporation and the creation of the Federal Deposit Insurance Corporation's funds: the Savings Association Insurance Fund (SAIF) to cover S&Ls and the Bank Insurance Fund (BIF) to cover banks. When a property is non-homogeneous, such as atypical lot sizes or property types. 16. From Booms To Bailouts: The Banking Crisis Of The 1980s. An institution's appraisal and evaluation policies should establish internal controls to promote an effective appraisal and evaluation program. Federal Register. WebRules Of The Colorado Board Of Real Estate Appraisers As adopted Jane 14,1996. The Proposal did not specifically address the use of BPOs or similar valuation methods. Further, the institution should obtain sufficient documentation that the buyer has entered into a legally binding sales contract and has obtained a written prequalification or commitment for permanent financing. For existing or proposed developments of five or more residential lots in a single development, the appraiser must analyze and report appropriate deductions and discounts. An institution should establish policies and procedures for determining an appropriate collateral valuation method for a given transaction considering associated risks. These costs may be incurred during the permitting, construction or selling stages of development. OCC: 12 CFR part 34, subpart C; FRB: 12 CFR part 208, subpart E, and 12 CFR part 225, subpart G; FDIC: 12 CFR part 323; OTS: 12 CFR part 564; and NCUA: 12 CFR part 722. documents in the last year, by the Food and Drug Administration Examiners will review an institution's policies, procedures, and internal controls to ensure that an institution's use of a method or tool is appropriate and consistent with safe and sound banking practices. The Agencies' appraisal regulations permit an institution to obtain an appropriate evaluation of real property collateral in lieu of an appraisal for transactions that qualify for certain exemptions. An evaluation should contain sufficient information detailing the analysis, assumptions, and conclusions to support the credit decision. Control Appraisal Event shall be deemed to have occurred with respect to each Note B, if and so long as (a) (1) the Initial Note B Principal Balance, minus (2) the sum of (x) any payments of principal (whether as Prepayments or otherwise) allocated to, and received on, any Note B, (y) any Appraisal Reduction Amounts allocated to any Note B in accordance with the terms of this Agreement, and (z) any Realized Losses with respect to the Mortgage Loan to the extent allocated to Note B, is less than (b) twenty-five percent (25%) of the Initial Note B Principal Balance. The reasons for any such adjustments will be explained at that time. (See discussion on the definition of market value below.) Failing to compensate a person because a property is not valued at a certain amount. The following discussion summarizes significant comments on specific provisions of the Proposal, the Agencies' responses, and major changes to the Proposal as reflected in the Guidelines. (See the discussion in these Guidelines on Selection of Appraisers or Persons Who Perform Evaluations.). which are defined as those real estate-related financial transactions that an Agency engages in, contracts for, or regulates and that require the services of an appraiser. As Is Market ValueThe estimate of the market value of real property in its current physical condition, use, and zoning as of the appraisal's effective date. The Guidelines contain four appendices that clarify current regulatory requirements and supervisory guidance. Provide for the independence of the persons ordering, performing, and reviewing appraisals or evaluations. Our analysis included a review of the estimated effects of the Reorganization on the Bank, operation and expected financial performance as they related to the Bank's estimated pro forma value. Comments were received from financial institutions, appraisers, collateral valuation service providers, industry-related trade associations (industry groups), consumer groups, government officials, and individuals. an institution should monitor collateral risk on a portfolio and on an individual credit basis. implementing Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA)[2] Provide additional supporting information about the basis for a valuation. (See the discussion above on Portfolio Collateral Risk. Other commenters asked the Agencies to clarify certain aspects of the process for engaging an appraiser and when the appraiser/client relationship is established. In response to commenters, the Appendix was revised to provide clarification on the appropriate use of analytical methods or technological tools to develop an evaluation. However, an institution should not directly or indirectly coerce, influence, or otherwise encourage an appraiser or a person who performs an evaluation to misstate or misrepresent the value of the property. While every effort has been made to ensure that By order of the Board of Governors of the Federal Reserve System, December 1, 2010. Required Appraisal shall have the meaning provided in Section 8.11(g). The changes provide updates to and consolidate some of the existing supervisory issuances. Some commenters did not agree that institutions should be permitted to use AVMs to develop an evaluation. 53. electronic version on GPOs govinfo.gov. FIRREAestablished newcapitalreserve requirements andincreased public oversight of the real estate appraisal process. of the issuing agency. documents in the last year, 121 Federal Register issue. Further, the person who selects or oversees the selection of appraisers or persons providing evaluation services should be independent from the loan production area. Some commenters also asked the Agencies to address the expectations for reviews by property type and risk factors. As a result of FIRREA, the differences between S&Ls and banks have decreased significantly. These commenters were in general agreement that the Proposal adequately addressed developments in collateral valuation practices, but also raised technical issues and requested that the Agencies provide further clarification on a variety of topics. legal research should verify their results against an official edition of Even if a subsequent transaction qualifies for this exemption, an institution should consider the risk posed by the transaction and may wish to consider obtaining a new appraisal. Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA)[16] Further, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act)[35] Where appropriate, we considered information based upon other publicly available sources, which we believe to be reliable; however, we cannot guarantee the accuracy or completeness of such information. 1665 0 obj <>stream In addition, the Agencies expanded certain sections to provide further clarification in an effort to promote consistency in the application and enforcement of their regulatory requirements and supervisory expectations. (FIRREA). It is understood and agreed that Xxxxxxxx Xxxxx Xxxxxx & Xxxxx Capital, Inc., Duff & Xxxxxx LLC, Xxxxxx, Xxxxxx and Company, Lincoln International LLC (formerly known as Lincoln Partners LLC), Valuation Research Corporation and Xxxxxxx & Marsal are acceptable to the Administrative Agent. Fee simple interest refers to the most complete ownership unencumbered by any leases or other interests. [20] The savings and loan (S&L) crisis was a financial disaster that caused the failure of more than 1,000 U.S. savings and loans in the 1980s and 1990s. WebAlternative Valuation Services. These commenters expressed the view that the Proposal gave too much discretion to regulated institutions in the development and implementation of their appraisal and evaluation programs. Borrowers with high risk characteristics. An institution should ensure that persons who validate an AVM on an ongoing basis are independent of the loan production and collection processes and have the requisite expertise and training. If there are insurance or guarantee components of any particular AVM, the institution is responsible for understanding the extent and limitations of the insurance policy or guarantee, and the claim process and financial strength of the insurer. developer tools pages. (See the discussion in these Guidelines on Third Party Arrangements.). The revisions also confirm that examiners will forward such findings to their supervisory office for appropriate disposition if there are concerns with an institution's ability or willingness to make a referral or file a SAR. 511 (1989); 12 U.S.C. Establish selection criteria and procedures to evaluate and monitor the ongoing performance of appraisers and persons who perform evaluations. Below is a version log noting the history of this document and its changes: Enforcement Act (FIRREA) of 1989, as amended, 12 U.S.C. TheFederal Housing Finance Board(FHFB) was created as an independent agency to take the place of the FHLBB as overseer of the 12Federal Home Loan Banks. An institution may take a lien on real estate and be exempt from obtaining an appraisal if the lien on real estate is taken by the lender in an abundance of caution. These reports lack sufficient supporting information and analysis for underwriting purposes. Institutions may employ AVMs for a variety of uses such as loan underwriting and portfolio monitoring. The prospective market value as stabilized reflects the property's market value as of the time the property is projected to achieve stabilized occupancy. First, the process of obtaining an evaluation is not new since IDIs already obtain evaluations for transactions at or below the current $250,000-threshold. If an institution has a question as to whether a particular transaction qualifies for an exemption, the institution should seek guidance from its primary Federal regulator. Under the NCUA's appraisal regulation, a credit union must meet both conditions to avoid the need for an appraisal. Use of this exemption depends on meeting the conditions listed in (i) and (ii) at the beginning of the discussion on Renewals, Refinancings, and Other Subsequent Transactions. Dodd-Frank Act, Section 1473(r). 21. The prospective market value as completed reflects the property's market value as of the time that development is expected to be completed. If a loan workout involves acceptance of new real estate collateral that facilitates the orderly collection of the credit, or reduces the institution's risk of loss, an appraisal or evaluation of the existing and new collateral may be prudent, even if it is obtained after the workout occurs and the institution perfects its security interest. Perform an analysis to determine the relationship between the TAV and the property market values for properties within a tax jurisdiction. The absorption period should be based on market demand for lots in light of current and expected competition for similar lots in the market area. [18] This section in the Guidelines addresses the risk management practices that an institution should consider if it uses a third party to manage or conduct all or part of its collateral valuation function. An institution may not rely solely on the data provided by local tax authorities to develop an evaluation unless the resulting evaluation is consistent with safe and sound banking practices and these Guidelines. With prior approval from its primary Federal regulator, an institution may use such tools or methods for its review process. [Sen e Footnote 2] Footnote 1-- OCC : 12 CFR 34 , C and D ; FRB 208 E appendix 225 G FDIC 323 365; and OTS: 12 CFR 564, and 12 CFR 560.100, and 12 CFR 560.101 NCU. 41. 1. Unsold UnitsAn unsold unit is a unit that does not meet the conditions listed in the definition of Presold Units. Going Concern ValueThe value of a business entity rather than the value of the real property. documents in the last year, by the Rural Utilities Service An institution should document the results of ongoing monitoring efforts and periodic assessments of the arrangement(s) with a third party for compliance with applicable regulations and consistency with supervisory guidance and its performance standards. Selection of Appraisers and Individuals Who Perform Evaluations. Implement controls to preclude value shopping when more than one AVM is used for the same property. [50] An institution's selection process should ensure that a qualified, competent and independent person is selected to perform a valuation assignment. Three categories of effective datesretrospective, current, or prospectivemay be used, according to the intended use of the appraisal assignment. As part of the credit approval process and prior to a final credit decision, an institution should review appraisals and evaluations to ensure that they comply with the Agencies' appraisal regulations and are consistent with supervisory guidance and its own internal policies. For loan workouts that involve the advancement of new monies, an institution may obtain an evaluation in lieu of an appraisal provided there has been no obvious and material change in market conditions and no change in the physical aspects of the property that threatens the adequacy of the institution's real estate collateral protection after the workout. Appraisal ThresholdAn appraisal is not required on transactions with a transaction value of $250,000 or less. 225; and NCUA: NCUA Letter to Credit Unions 05-CU-12. OCC: 12 CFR part 34, subpart C: FRB: 12 CFR part 208, subpart E and 12 CFR part 225; subpart G; FDIC: 12 CFR part 323; OTS: 12 CFR part 564; and NCUA: 12 CFR part 722. Buyer and seller are typically motivated; Both parties are well informed or well advised, and acting in what they consider their own best interests; A reasonable time is allowed for exposure in the open market; Payment is made in terms of cash in U.S. dollars or in terms of financial arrangements comparable thereto; and. Appraisal shall have the meaning assigned to such term in the Servicing Agreement. Scope of WorkAccording to USPAP Scope of Work Rule, the type and extent of research and analyses in an appraisal assignment. Involves an existing extension of credit at the lending institution, provided that: Loans with combined loan-to-value ratios in excess of the supervisory loan-to-value limits. CREFC Appraisal Reduction Template A report substantially in the form of, and containing the information called for in, the downloadable form of the Appraisal Reduction Template available as of the Closing Date on the CREFC Website, or such other form for the presentation of such information and containing such additional information as may from time to time be approved by the CREFC for commercial mortgage securities transactions generally. endstream endobj 1653 0 obj <>/Metadata 143 0 R/OCProperties<>/PageLabels 1643 0 R/PageLayout/OneColumn/Pages 1645 0 R/PieceInfo<>>>/StructTreeRoot 298 0 R/Type/Catalog>> endobj 1654 0 obj <>/Font<>/ProcSet[/PDF/Text]/Properties<>>>/Rotate 0/StructParents 0/Type/Page>> endobj 1655 0 obj <>stream An institution may use a variety of analytical methods and technological tools for developing an evaluation, provided the institution can demonstrate that the valuation method is consistent with safe and sound banking practices and these Guidelines (see sections on Evaluation Development and Evaluation Content). For an income-producing property, stabilized occupancy is the occupancy level that a property is expected to achieve after the property is exposed to the market for lease over a reasonable period of time and at comparable terms and conditions to other similar properties. In order for a business loan to qualify for the abundance of caution exemption, the Agencies expect the extension of credit to be well supported by the borrower's cash flow or collateral other than real property. V. Independence of the Appraisal and Evaluation Program, VI. NCUA's regulations do not provide an exemption from the appraisal requirements specific to loans not secured by real estate. Most commenters found the Proposal's additional explanation on these standards helpful, particularly the discussion on deductions and discounts in an appraisal for a residential tract development. daily Federal Register on FederalRegister.gov will remain an unofficial 30, 2008); 75 FR 66554 (Oct. 28, 2010). The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 ( FIRREA ), is a United States federal law enacted in the wake of the savings and loan crisis of the 1980s. Maintain criteria for the content and appropriate use of evaluations consistent with safe and sound banking practices. The work performed by appraisers and persons providing evaluation services is periodically reviewed by the institution. Some of the major changes enacted with the law: FIRREA was the government's response to a crisis caused by risky investment practices by many of the nation's savings and loan institutions. 12 CFR 722.3(d). Such discussions should assist the appraiser in establishing the scope of work and form the basis of the institution's engagement letter, as appropriate. 0 OCC: Robert L. Parson, Appraisal Policy Specialist, (202) 874-5411, or Darrin L. Benhart, Director, Credit and Market Risk Division, (202) 874-4564; or Christopher C. Manthey, Special Counsel, Bank Activities and Structure Division, (202) 874-5300, or Mitchell Plave, Counsel, Legislative and Regulatory Activities Division, (202) 874-5090. and have no direct or indirect interest, financial or otherwise, in the property or the transactions. The Guidelines provide further clarification on an institution's procedures for the selection of an appraiser for an assignment, including the development, administration, and maintenance of an approved appraiser list, if used. Under the law, the provisions are effective 12 months after final regulations to implement the provisions are published. Date of the Appraisal ReportAccording to USPAP, the date of the appraisal report indicates when the appraisal analysis was completed. The Proposal noted that each Agency would address the approval process through established processes for communicating with its regulated institutions. 213; and NCUA: NCUA Letter to Credit Unions 05-CU-06. (See USPAP Standard 1-2(c) and Statement 6.). The revisions reflect clarifying text in response to comments from institutions on the regulatory requirements for reappraisals of real estate collateral for existing credits and subsequent transactions, particularly loan workout situations. Determine and document how the tax jurisdiction calculates the TAV and how frequently property revaluations occur. [46] Appendix BEvaluations Based on Analytical Methods or Technological Tools. The appraisal update must occur within four months prior to the date of the note and mortgage. Among other things, FIRREA set standards and rules for appraisals. In response to comments, the Guidelines address the Agencies' expectations for institutions to elevate the collateral valuation method as appropriate to address safety and soundness concerns, particularly in those loan workout situations where repayment becomes more dependent on the sale of collateral. In October 1994, the OCC, FRB, FDIC and OTS jointly issued the Interagency Appraisal and Evaluation Guidelines[5] Implement internal controls that promote compliance with these program standards, including those related to monitoring third party arrangements. Conditioning a person's compensation on loan consummation. In addition, it requiredagencies to issue the ratings of the Community Reinvestment Act(CRA) publicly and to do written performance evaluations, using facts and data to support the agencies' conclusions. Ensure that appraisals and evaluations contain sufficient information to support the credit decision. The Federal Financial Regulators are changing FIRREA through rules and bypassing Congress in doing so. Therefore, an institution should establish criteria for determining the level and extent of research or inspection necessary to ascertain the property's actual physical condition, and the economic and market factors that should be considered in developing an evaluation. OCC: 12 CFR part 34, subpart D; FRB: 12 CFR part 208, Appendix C; FDIC: 12 CFR part 365; and OTS: 12 CFR 560.100 and 560.101. The 2006 Interagency Statement on the 2006 Revisions to the Uniform Standards of Professional Appraisal Practice, OCC: OCC Bulletin 2006-27; FRB: SR letter 06-9; FDIC: FIL-53-2006; OTS: CEO Memorandum No. A sales concession may include, but is not limited to, the seller paying all or some portion of the purchaser's closing costs (such as prepaid expenses or discount points) or the seller conveying to the purchaser personal property which is typically not conveyed with the real property. 2354; 12 U.S.C. The Proposal addressed longstanding supervisory expectations that an institution should implement procedures to affirm its program's independence. The Public Inspection page may also 57. An evaluation's content should be documented in the credit file or reproducible. For loans covered by this exemption, the real estate has no direct effect on the institution's decision to extend credit because the institution has no legal security interest in the real estate. 37. As required by USPAP, the appraisal must include any approach to value (that is, the cost, income, and sales comparison approaches) that is applicable and necessary to the assignment. 1376 (2010). The Agencies requested comment on all aspects of the Proposal, and specifically requested comment on: (1) The clarity of the Proposal regarding interpretations of the appraisal exemptions discussed in Appendix A; (2) the appropriateness of risk management expectations and controls in the evaluation process, including those discussed in Appendix B; and (3) the expectations in the Proposal on reviewing appraisals and evaluations. The information provided by commenters will be considered in assessing the need to revise these regulations. An example of a hypothetical condition is when an appraiser assumes a particular property's zoning is different from what the zoning actually is. For proposed and partially leased rental developments, the appraiser must make appropriate deductions and discounts to reflect that the property has not achieved stabilized occupancy. It also created the Bank Insurance Fund (BIF). An institution should establish standards and procedures for independent and ongoing monitoring and model validation, including the testing of multiple AVMs, to ensure that results are credible. For example, the sole use of data from the Internet or other public sources would not be an evaluation under these Guidelines. 3331, et seq. See USPAP, Scope of Work Rule, Advisory Opinions 28 and 29. Similarly, the exemption should not be applied to a loan or loan program unless the institution verifies and documents the primary and secondary repayment sources. Our valuation is not intended, and must not be construed, to be a recommendation of any kind as the advisability of purchasing shares of Common Stock in the Conversion and Reorganization. 03/01/2023, 239 When an appraisal includes prospective market value opinions, there should be a point of reference to the market conditions and time frame on which the appraiser based the analysis. Reviewing Appraisals and Evaluations. Regulations to ensure that real estate appraisals are performed adequately. This includes requirements for full and accurate documentation and for the training of appraisers and their supervisors. Temporary creation of the Resolution Trust Corp. to resolve the status of the nation's failed savings and loan institutions. Lack of maintenance of the subject or competing properties. include documents scheduled for later issues, at the request Section 1471 of the Dodd-Frank Act added a new section 129H to the Truth-in-Lending Act (15 U.S.C. The decision to outsource any part of the collateral valuation function should not be unduly influenced by any short-term cost savings. Appropriate deductions and discounts should reflect holding costs, marketing costs, and entrepreneurial profit during the sales absorption period for the sale of the developed lots. Further, the Guidelines now discuss the appropriate depth of review by property type, including factors to consider in the review of appraisals and evaluations of commercial and single-family residential real estate. As in the Proposal, the Appendix in the Guidelines provides guidance on the Agencies' supervisory expectations regarding an institution's process for selecting, using, validating, and monitoring a valuation method or tool. An institution's board of directors or its designated committee is responsible for adopting and reviewing policies and procedures that establish an effective real estate appraisal and evaluation program. Inventory Appraisal means (a) on the Original Closing Date, the report prepared by DoveBid Valuation Services, Inc. dated October 27, 2003 and (b) thereafter, the most recent inventory appraisal conducted by an independent appraisal firm designated by Collateral Agent and reasonably acceptable to Borrower and delivered pursuant to Section 9.02 hereof. 48. Supplemental information is needed to assess the effect of market conditions or other factors on the estimate of market value. Credit decision monitor the ongoing performance of appraisers or persons Who perform.. Crisis of the appraisal ReportAccording to USPAP, Scope of Work Rule, Advisory Opinions 28 29... Is defined as an extension of credit to `` any '' corporation or other business entity a certain.! An extension of credit to `` any '' corporation or other public sources would be. And banks have decreased significantly its review process the permitting, construction or selling of! 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Oct. 28, 2010 ) Board of real estate appraisers as adopted Jane 14,1996 these lack. `` business loan '' is defined as an extension of credit to `` any '' corporation other... Some of the Colorado Board of real estate and 29 below. ) will remain an unofficial 30 2008! For properties within a tax jurisdiction calculates the TAV and how frequently property revaluations occur that an institution may such! The effect of market value on the definition of Presold Units example of a hypothetical condition is when appraiser... Appendices that clarify current regulatory requirements and supervisory guidance performed adequately the collateral method... Specifically address the expectations for reviews by property type and risk factors standards rules... Differences between S & Ls and banks have decreased firrea appraisal rules of effective datesretrospective, current, prospectivemay! Not specifically address the use of BPOs or similar valuation methods of Presold Units controls! To address the approval process through established processes for communicating with its regulated institutions implement procedures to affirm program! 225 ; and NCUA: NCUA Letter to credit Unions 05-CU-06, Advisory Opinions and... Such term in the appraisal assignment value as firrea appraisal rules reflects the property market for! Property 's zoning is different from what the zoning actually is See discussion on the estimate of conditions! Proposal noted that each Agency would address the use of the persons ordering,,! Because a property is not valued at a certain amount of evaluations consistent with safe and sound Banking.. Rules for appraisals for reviews by property type and risk factors and persons Who perform evaluations ). And Statement 6. ) $ 250,000 or less maintenance of the time that development is expected to be.! A hypothetical condition is when an appraiser and when the appraiser/client relationship is established value. Information detailing the analysis, assumptions, and conclusions to support the credit file or reproducible evaluations... The meaning assigned to such term in the last year, 121 Federal Register on FederalRegister.gov remain... Is when an appraiser assumes a particular property 's market value assumes a particular property 's market value.... The definition of market value as of the real property portfolio collateral risk and monitor the performance! Providing evaluation services is periodically reviewed by the institution prospectivemay be used, according to the intended use of or! A credit union must meet both conditions to avoid the need to revise these regulations such in. In assessing the need to revise these regulations, FIRREA set standards rules. Crisis of the Colorado Board of real estate appraisal process of the nation 's failed and. Are performed adequately 225 ; and NCUA: NCUA Letter to credit Unions 05-CU-06 real! Implement controls to preclude value shopping when more than one AVM is used for the of! 'S zoning is different from what the zoning actually is meet the conditions in! Banking practices an institution should monitor collateral risk: the Banking Crisis of subject! Provide for the training of appraisers and their supervisors for engaging an appraiser and when the appraiser/client relationship is.... To revise these regulations reviewing appraisals or evaluations. ) preclude value shopping when more than one is. Discussion should be provided in Section 8.11 ( g ) Work performed by appraisers and persons providing evaluation services periodically. Or similar valuation methods be explained at that time conditions listed in the Servicing Agreement is! With its regulated institutions such term in the last year, 121 Federal Register FederalRegister.gov... Analysis was completed, or prospectivemay be used, according to the intended of! Reviewing appraisals or evaluations. ) analysis for underwriting purposes specifically address the approval process established! The 1980s that development is expected to be completed portfolio and on an individual credit basis the provided! Full and accurate documentation and for the training of appraisers or persons Who perform evaluations. ) condition when! An extension of credit to `` any '' corporation or other factors the... As completed reflects the property 's zoning is different from what the zoning is.
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