Publications:
2004 Survey of Credit Underwriting Practices
National Credit Committee
September 2004

Commercial Lending Portfolios

Agricultural Lending

Twenty-nine of the 72 banks in the survey were engaged in some form of agricultural lending.

Changes in Underwriting Standards in Agricultural Loan Portfolios
(Percent of Banks)

Eased Unchanged Tightened

1997
8
79
13

1998
18
74
8

1999
3
79
18

2000
3
71
26

2001
3
71
26

2002
0
70
30

2003
0
67
33

2004
0
93
7

Changes in Level of Credit Risk in Agricultural Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
6
42

49
3

2000
0
15
41

44
0

2001
0
17
43

34
6

2002
0
7
63

30
0

2003
0
11
48

41
0

2004
0
10
59

31
0

Future 12 Months
0
17
66

17
0

Asset-Based Loans

Thirty-one of the surveyed banks were engaged in this type of lending.

Changes in Underwriting Standards in Asset-Based Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	10	78	12
2000	11	67	22
2001	5	53	42
2002	3	66	31
2003	0	58	42
2004	16	71	13

Changes in Level of Credit Risk in Asset-Based Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
10
66

24
0

2000
0
8
62

30
0

2001
5
8
42

45
0

2002
0
0
50

50
0

2003
3
26
42

29
0

2004
3
29
55

13
0

Future 12 Months
0
13
64

23
0

Commercial Real Estate Lending-Commercial Construction

Fifty-nine of the 72 banks in the survey were engaged in commercial real estate lending.

Changes in Underwriting Standards in Commercial Construction Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
2003	2	61	37
2004	10	75	15

Changes in Level of Credit Risk in Commercial Construction Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

2003
0
7
46

42
5

2004
0
7
59

34
0

Future 12 Months
0
5
70

25
0

Commercial Real Estate Lending-Residential Construction

Fifty-five of the 72 banks in the survey were engaged in residential construction real estate lending.

Changes in Underwriting Standards in Residential Construction Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
2003	0	76	24
2004	5	86	9

Changes in Level of Credit Risk in Residential Construction Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

2003
0
2
62

34
2

2004
0
4
76

18
2

Future 12 Months
0
4
69

27
0

Commercial Real Estate Lending-Other

Sixty-five of the 72 banks in the survey were engaged in other commercial real estate lending.

Changes in Underwriting Standards in Other Commercial Real Estate Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
2003	5	71	24
2004	8	83	9

Changes in Level of Credit Risk in Other Commercial Real Estate Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

2003
0
5
48

43
4

2004
0
12
66

20
2

Future 12 Months
0
8
68

23
1

International Lending

Only 18 of the 72 banks in the survey were active in international lending.

Changes in Underwriting Standards in International Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	4	54	42
2000	14	72	14
2001	29	57	14
2002	11	61	28
2003	6	55	39
2004	11	61	28

Changes in Level of Credit Risk in International Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
8
8
42

38
4

2000
0
33
53

14
0

2001
0
14
53

33
0

2002
0
22
39

28
11

2003
0
6
55

33
6

2004
6
33
55

6
0

Future 12 Months
6
11
61

22
0

Middle Market Lending

Fifty-six of the 72 banks in the survey were engaged in middle market lending.

Changes in Underwriting Standards in Middle Market Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	18	73	9
2000	18	66	16
2001	11	48	41
2002	0	60	40
2003	6	63	31
2004	14	81	5

Changes in Level of Credit Risk in Middle Market Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
8
56

36
0

2000
0
2
50

46
2

2001
0
2
35

59
4

2002
2
8
22

66
2

2003
0
13
39

44
4

2004
0
28
52

18
2

Future 12 Months
2
16
57

25
0

Small Business Lending

Fifty-four of the 72 banks in the survey are lending in the small business market.

Changes in Underwriting Standards in Small Business Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	13	75	12
2000	8	73	19
2001	5	63	32
2002	2	66	32
2003	4	65	31
2004	11	74	15

Changes in Level of Credit Risk in Small Business Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
8
67

23
2

2000
0
3
72

22
3

2001
0
3
60

37
0

2002
0
2
56

40
2

2003
0
4
56

38
2

2004
0
15
72

13
0

Future 12 Months
0
13
57

30
0

Structured Finance

Twenty of the 72 banks in the survey provided structured finance loans.

Changes in Underwriting Standards in Structured Finance Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	24	44	32
2000	35	45	20
2001	0	4	96
2002	0	44	56
2003	0	48	52
2004	15	85	0

Changes in Level of Credit Risk in Structured Finance Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
4
36

56
4

2000
0
0
20

80
0

2001
0
4
8

46
42

2002
0
7
26

52
15

2003
10
33
28

29
0

2004
15
40
40

5
0

Future 12 Months
0
40
50

10
0

Syndicated/National Credits

Thirty-six of the 72 banks in the survey were active in the syndicated/national credit market.

Changes in Underwriting Standards in Syndicated/National Credit Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	18	50	32
2000	22	61	17
2001	0	34	66
2002	0	45	55
2003	3	49	48
2004	17	66	17

Changes in Level of Credit Risk in Syndicated/National Credit Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0
0
45

45
10

2000
0
0
36

61
3

2001
0
6
17

63
14

2002
0
8
29

53
10

2003
5
27
33

30
5

2004
17
36
36

11
0

Future 12 Months
0
31
58

11
0

Retail Lending Portfolios

Affordable Housing Lending

For the purposes of this survey, affordable housing loans included all types of loans on affordable housing for low- and moderate-income individuals and families, including single- to four-family and multifamily dwellings. Thirty-five of the 72 banks in the survey were reported to be making affordable housing loans.

Changes in Underwriting Standards in Affordable Housing Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	16	70	14
2000	10	84	6
2001	6	88	6
2002	3	91	6
2003	3	88	9
2004	6	86	8

Changes in Level of Credit Risk in Affordable Housing Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
2

2

78

18

0

2000
0

6

83

11
0

2001
2

2

88

8

0

2002
0

6

73

21
0

2003
0

9

76

15
0

2004
0

9

82

9

0

Future 12 Months
0

0

86

14

0

Consumer Leasing

Consumer leasing was offered by 14 of the 72 banks in the survey.

Changes in Underwriting Standards in Consumer Leasing Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	5	54	41
2000	0	50	50
2001	0	56	44
2002	0	67	33
2003	0	69	31
2004	0	86	14

Changes in Level of Credit Risk in Consumer Leasing Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0

5

50

45
0

2000
0

5

67

28
0

2001
6

11

39

44
0

2002
7

13

26

47

7

2003
8

15

69

8
0

2004
43

21

36

0

0

Future 12 Months
29

43

21

7

0

Credit Card Lending

Twenty-eight of the 72 banks in the survey were engaged in credit card lending.

Changes in Underwriting Standards in Credit Card Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	8	66	26
2000	9	75	16
2001	16	60	24
2002	12	66	22
2003	19	62	19
2004	18	61	21

Changes in Level of Credit Risk in Credit Card Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0

13

47

36

4

2000
0

16

66

16

2

2001
8

5

57

27

3

2002
0

6

54

31

9

2003
0

22

48

30

0

2004
0

11

61

25

3

Future 12 Months
0

18

57

21

4

Direct Consumer Lending

Fifty-six of the 72 banks in the survey were engaged in direct consumer lending.

Changes in Underwriting Standards in Other Direct Consumer Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	7	74	19
2000	10	78	12
2001	7	73	20
2002	2	67	31
2003	8	68	24
2004	3	86	11

Changes in Level of Credit Risk in Other Direct Consumer Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0

7

65

28

0

2000
0

9

74

15

2

2001
0

7

71

20

2

2002
2

6

67

25
0

2003
2

17

72

7

2

2004
2

13

78

7

0

Future 12 Months
0

7

79

14

0

Home Equity - Conventional Lending

Sixty-one of the 72 banks in the survey offered the conventional home equity lending product.

Changes in Underwriting Standards in Home Equity - Conventional Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	23	67	10
2000	23	64	13
2001	7	70	23
2002	0	74	26
2003	18	63	19
2004	13	77	10

Changes in Level of Credit Risk in Home Equity - Conventional Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0

0

69

29

2

2000
0

5

73

20

2

2001
0

11

74

13

2

2002
0

7

71

22

0

2003
4

4

69

23
0

2004
0

6

79

13

2

Future 12 Months
0

0

67

33

0

Home Equity - High LTV Lending

Twenty-eight of the 72 banks in the survey offered the high LTV home equity lending product.

Changes in Underwriting Standards in Home Equity - High LTV Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	20	61	19
2000	21	55	24
2001	11	54	35
2002	0	56	44
2003	7	68	25
2004	18	71	11

Changes in Level of Credit Risk in Home Equity - High LTV Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
0

6

47

44

3

2000
0

13

58

24

5

2001
5

11

62

16

6

2002
0

12

40

44

4

2003
0

11

50

36

3

2004
0

18

61

18

3

Future 12 Months
0

7

57

36

0

Indirect Consumer Leasing

Thirty-five of the 72 banks in the survey were engaged in indirect consumer lending.

Changes in Underwriting Standards in Indirect Consumer Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	7	56	37
2000	7	60	33
2001	7	63	30
2002	0	72	28
2003	5	65	30
2004	11	60	29

Changes in Level of Credit Risk in Indirect Consumer Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
2

23

42

33

0

2000
7

16

55

22

0

2001
2

21

39

33

5

2002
3

13

38

43

3

2003
5

20

47

28

0

2004
0

26

60

14

0

Future 12 Months
0

14

60

26

0

Residential Real Estate Lending

Sixty-two of the 72 surveyed banks were engaged in residential real estate lending.

Changes in Underwriting Standards in Residential Real Estate Loan Portfolios
(Percent of Banks)

	Eased	Unchanged	Tightened
1999	14	77	9
2000	7	85	8
2001	12	72	16
2002	4	83	13
2003	2	86	12
2004	7	86	7

Changes in Level of Credit Risk in Residential Real Estate Loan Portfolios
(Percent of Banks)

Declined Significantly Declined Somewhat Unchanged Increased Somewhat Increased Significantly

1999
3

5

71

21

0

2000
0

3

83

12

2

2001
0

9

76

15

0

2002
0

8

68

24

0

2003
0

12

74

12

2

2004
0

6

92

2

0

Future 12 Months
0

2

79

19

0

Part I - Overall Results

Part II - Graphs

The Office of the Comptroller of the Currency was created by Congress to charter national banks, to oversee a nationwide system of banking institutions, and to assure that national banks are safe and sound, competitive and profitable, and capable of serving in the best possible manner the banking needs of their customers.

Publications:2004 Survey of Credit Underwriting PracticesNational Credit CommitteeSeptember 2004Commercial Lending Portfolios

Publications:
2004 Survey of Credit Underwriting Practices
National Credit Committee
September 2004

Commercial Lending Portfolios