Regulatory Alerts2005-07-26 | ISGC-2005-010-DOBWashington State Department of Financial Institutions Interpretive Statement on Houseboat Lending and FFIEC Credit Risk Ratios
The Washington State Department of Financial Institutions issued an interpretive statement clarifying that houseboats are personal property rather than real estate for lending purposes. Consequently, the Division mandates that banks apply the 100% credit risk ratio designated for consumer loans instead of the 50% ratio reserved for real estate loans under FFIEC guidelines. This determination remains in effect despite arguments for federal parity, citing the inherent legal and underwriting risks associated with houseboat moorage and collateral security.
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