[Name deleted]

Dear [name deleted]:

This is in response to your letters dated July 17 and August 31, 1998, requesting, on behalf of [BHC], an opinion regarding whether certain activities that [BHC] proposes to conduct through [name deleted] ("ALI"), a joint venture,¹ would be within the scope of activities related to extending credit as defined in section 225.28(b)(2) of Regulation Y (12 C.F.R. 225.28(b)(2)). [BHC] proposes to engage through ALI in conducting training seminars on a fee basis for officers and employees of banks, consumer finance companies, and other consumer lending institutions. The seminars would provide participants with information regarding the business and legal aspects of loan customer solicitation, loan processing and documentation, credit insurance products, loan servicing, and specialty lending.

The Board has determined, in section 225.28(b)(2) of Regulation Y, that it is permissible for bank holding companies to engage in "[a]ny activity usual in connection with making, acquiring, brokering, or servicing loans or other extensions of credit, as determined by the Board." 12 C.F.R. 225.28(b)(2). The proposed training seminars discussed in the preceding paragraph are intended and designed to help train officers and employees of banks and consumer lending companies regarding various procedures, practical difficulties, and legal issues that arise in conducting the business of extending credit to consumers. You have indicated that all topics covered in the training seminars would be related to consumer lending, such as the solicitation of consumer borrowers, the processing, documenting, and servicing of consumer loans, and compliance with the Truth in Lending Act, the Real Estate Settlement Procedures Act, and other consumer lending statutes. You have also indicated that two of your joint venture partners would likely be law firms, and that ALI has received an opinion of the Alabama State Bar that ALI will not be engaged in the practice of law by virtue of conducting the seminars.

In light of all the facts of record, we believe that the proposed services described in this letter are within the scope of permissible activities related to extending credit under section 225.28(b)(2) of Regulation Y (12 C.F.R. 225.28(b)(2)).

This opinion is limited solely to the proposed activities described above, and does not address the treatment of any other activities or authorize ALI to engage in any other activities. Any material change in the proposed activities described above may require this opinion to be reconsidered and should be communicated immediately to Board staff.

Very truly yours,

(Signed) Scott G. Alvarez

Scott G. Alvarez

cc: Federal Reserve Bank of Atlanta

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