FDIC Calls for Consideration of Junior Liens

FDIC Comment Form The FDIC Office of the Ombudsman is a confidential, neutral, and independent source of assistance to anyone affected by the FDIC in its regulatory role. We aid in the resolution of complaints by listening, clarifying issues, and working with internal and external parties to reach an acceptable solution.

The policy should require that consideration of these factors takes place before foreclosure on the senior lien or delinquency of the junior lien. The policy should also explain how management’s consideration of these factors affects income recognition prior to foreclosure on the senior lien or delinquency of the junior lien to ensure income is not overstated.

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The line of credit is junior to the purchase-money mortgage, but it is senior to the Association’s assessment lien. And the assessment lien is junior to both the prior liens. Any later liens to be recorded will take priority according to what order they are recorded in. Whoever records before another would be in "senior" position and the.

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On January 31, 2012, the Board of Governors of the Federal Reserve System, the Federal deposit insurance corporation, the National credit union administration and the Office of the Comptroller of the Currency (collectively, the agencies) issued Interagency Supervisory Guidance on Allowance for Loan and Lease losses (alll) estimation practices for Loans and Lines of Credit Secured by Junior.

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