No, the lending limits for savings associations do not entirely mirror those for national banks, although the lending limits for both types of institutions will remain at 15% for unsecured lending and 25% for secured lending. When the OCC consolidated the OCC lending limit rules with the former OTS rules in 2012, it retained certain lending limit exceptions that apply only to savings associations in a separate subsection (subsection (d) of 12 CFR 32.3), meaning that the lending limits for savings associations continue to differ from those applying to national banks. The OCC also retained the general lending limits for savings associations, which have always been 15% of the institution’s capital and surplus, plus an additional 10% (totaling 25%) for loans that are fully secured, subject to the exceptions for savings associations in subsection (d).

For resources related to our guidance, please see:

• OCC Lending Limit Rules, 12 CFR 32.3 (lending limits applying to both national banks and savings associations, with special lending limit exceptions for savings associations in subsection 32.3(d))
• 77 Federal Register 37265 (June 21, 2012) (expands the scope of the OCC lending limit rules in Section 32 to cover savings associations, eliminates the former savings association lending limit rules in 12 CFR 160.93, and adds the exceptions for savings associations in a new subsection 32.3(d))