United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on Financial Institutions and Regulatory

Relief, Committee on Banking, Housing,

and Urban Affairs, U.S. Senate

August 1998 LIVE LOAN CHECKS

Information on

Unsolicited Consumer

Loans for Preapproved

Borrowers

GAO/GGD-98-176

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-279852 

August 14, 1998

The Honorable Lauch Faircloth

Chairman, Subcommittee on Financial

 Institutions and Regulatory Relief

Committee on Banking, Housing, and Urban Affairs

United States Senate

Dear Mr. Chairman:

This report responds to your request that we provide information on live

loan checks. Live loan checks are preapproved loans extended to potential

borrowers by sending them unsolicited, negotiable checks. When

recipients sign, then subsequently cash or deposit the checks, they obtain

the loans. Lenders preapprove recipients for these live loan checks after

assessing their creditworthiness.

As agreed with your office, this report provides available information

concerning (1) the characteristics of live loan checks and the major

organizations that provide unsolicited loan checks; (2) the volume of live

loan checks in 1995, 1996, and 1997 and the expected volume in 1998; and

(3) the benefits and risks of live loan checks for the borrowers and

lenders. We also agreed to provide available information on losses

associated with live loan checks.

To compile this information, we interviewed officials representing federal

regulatory agencies, one banking association, one rating agency, one

consumer advocacy group, and three lending institutions (lenders)

offering live loan checks. We also reviewed publicly available information,

including published reports on live loan check issues and industry

standards for live loan checks. Limited information exists on live loan

check volume and losses industry-wide, and we relied primarily on

specific lending institution data. While we did not independently verify

these data, we corroborated evidence with other independent sources

whenever possible. We conducted our work between January and

June 1998.

Results in Brief Once cashed, live loan checks result in unsecured consumer loans.1

 Bank

officials we interviewed told us that live loan checks are aimed at the most

creditworthy customers—that is, those least likely to be delinquent or in

default in making loan payments. According to Fleet Bank (Fleet) and

1

Unsecured loans are not backed by collateral.

Page 1 GAO/GGD-98-176 Live Loan Checks
B-279852 

Chase Manhattan (Chase) officials, such loans are made at interest rates

ranging from 12.9 percent to 15.9 percent, compared to an average

16 percent for credit cards.2

 Fleet officials told us that it has sent potential

borrowers live loan checks ranging from $3,000 to $10,000 based on its

estimate of the borrower’s ability to repay the loan. The repayment terms

for these loans ranged from 48 months to 60 months, and the loans were

amortized.3

 Fleet officials stated that borrowers generally have used the

loan amounts for expenses such as home improvements, debt

consolidation, and school expenses.

According to bank officials we interviewed, at least eight financial

institutions have offered live loan checks. Of these eight financial

institutions, six were banks: Chase, Fleet, First USA Bank, Signet Bank,4

BancOne Corporation, and First Chicago NBD. Two were nonbanks:5

Capital One and Beneficial Corporation. First Chicago stopped offering

these loans after suffering a level of losses that it considered “not

acceptable” during a pilot program.

Public and private sector officials told us that comprehensive data on the

volume of live loan checks were not available and that no one was

tracking volume data. One institution—Fleet—provided us with

quantitative data on its live loan check program. Between 1995 and 1997,

Fleet mailed 4.35 million live loan checks. Of these, approximately 155,000

borrowers cashed the checks and accepted the loans. Fleet made over

$680 million in loans through this program. Fleet officials told us that it

experienced 68 confirmed cases of fraud, which generally involved

someone other than the intended recipient cashing the check.

Public and private sector officials identified benefits and risks associated

with live loan checks for both borrower and lenders. In the views of these

officials, borrowers benefit from live loan checks because these checks

meet their needs for immediate access to funds at interest rates

competitive with those offered by credit cards. Risks to the borrowers

2

According to the Federal Reserve, as of May 7, 1998, this was the average interest rate charged by

commercial banks for credit cards.

3

Amortization is the reduction of a debt by periodic payments of interest and principal on an unpaid

loan balance for the life of the loan.

4

On March 20, 1998, First Union Corporation purchased Signet Bank.

5

The U.S. Congress defines a commercial bank as an institution that (1) accepts deposits that the

depositor has a legal right to withdraw on demand, and (2) engages in the business of making

commercial loans. This statutory definition is important because, by not engaging in either of these

special activities, a corporation can own and operate an institution that otherwise operates like a

bank, without being subject to Federal Reserve regulation as a bank holding company. Financial

institutions that fit this mold have been referred to as nonbanks.

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B-279852 

include the potential for these loans to compound problems associated

with high levels of consumer borrowing. In fraud situations, losses are to

be absorbed by the bank and/or the institution honoring the check, rather

than by the borrower. A consumer advocacy group official noted,

however, that the potential borrower may face considerable

inconvenience in correcting personal credit records after a forged

endorsement occurs.

Two lenders—Fleet and Chase—informed us that, while loans initiated

from cashing live loan checks were a small percentage of their bank

assets, the programs thus far have been profitable, with manageable risks.

They said that losses were managed by targeting the loans to the most

creditworthy borrowers. However, one lender—First

Chicago—discontinued offering these loans after suffering losses during a

pilot program.

Background According to the American Financial Services Association (AFSA),6

 some of

its members have been issuing live loan checks since the 1980s. Live loan

checks are delivered in the mail and are preapproved offers of credit.

Consumers are selected to receive the loan offers if they meet certain

credit criteria.

These preapproved offers of credit are based, in part, on a consumer’s

credit score. Credit bureaus develop scores by assessing various types of

information collected from a large pool of borrowers, including borrowers

with good payment histories and others with poor payment histories, to

estimate the credit risk7

 associated with different types of loans. Credit

scoring systems use statistical analysis to identify and weigh the

characteristics of borrowers who have been most likely to make loan

payments. For example, borrowers with little or no history of delinquent

payments receive higher credit scores than borrowers with many

delinquent payments. Most widely used credit scoring systems have a

range of scores from 350 to 900. Borrowers with higher scores are

considered more creditworthy because they are more likely to repay the

loan on time and in full than are borrowers with lower credit scores.8

6

Founded in 1916, AFSA is a trade association for a wide variety of market-funded providers of

financial services to consumers and small businesses.

7

Credit risk is the risk that an obligation will not be paid on a timely basis.

8

Even though borrowers with higher scores could become delinquent or default and some borrowers

with lower scores could pay the loan as required, statistics show that borrowers with higher scores are

more likely to pay the loan on time, and in full, than are borrowers with lower scores.

Page 3 GAO/GGD-98-176 Live Loan Checks
B-279852 

Live Loan Checks

Have Certain

Characteristics

While comprehensive data on live loan checks are not available, data

provided by one lender depict its loans as amortizing loans with interest

rates below credit card rates. According to this lender, the recipients of its

live loan checks had high credit scores and good credit histories. Chase

and Fleet officials provided us with the materials they sent to the

recipients of live loan checks. The materials include information

disclosing that the check represents a loan and presenting the terms and

conditions of the loan. Voluntary industry standards also call for such

disclosure.

Average Live Loan Check

Profile

Comprehensive industry data on the average live loan check and the

borrower using this product are not available. Fleet and Chase officials,

however, provided us with information on their live loan check profile.

According to Fleet, borrowers receive live loan checks ranging from

$3,000 to $10,000, based on the lender’s estimate of the recipient’s

predicted ability to repay the loan. Prior to selection, recipients had

demonstrated their ability to manage debt by having satisfactory payment

histories. According to Fleet and Chase officials, interest rates on loans

resulting from live loan checks have ranged from 12.9 percent to

15.9 percent. The repayment terms for these loans ranged from 48 months

to 60 months and are amortized. In addition, Fleet’s live loan checks

generally were only valid for 6 weeks from the date of issuance;9

 this

provision is intended to lessen the risk of using outdated credit data as a

basis for assessing a potential borrower’s creditworthiness.

Average Live Loan Check

Borrower’s Profile

Borrowers’ credit scores were used as the primary factor in determining

whether to offer a live loan check, and credit criteria were conservative in

the lender’s view. Fleet officials told us that their borrowers had an

average credit score of 730, with a minimum cut-off of 690. A credit score

of 730, for example, implies odds of 125 to 1 against defaulting on an

unsecured loan—that is, the estimated probability of default is less than

1 percent. The officials said that Fleet borrowers primarily resided within

the established franchise area where the bank offers retail banking

services.10 The borrower had a median household income of $44,000.11 In

addition to having to meet a minimum credit score, borrowers also were to

9

According to industry standards, live loan checks can be valid for 6 months.

10Fleet’s franchise area comprises Maine, Connecticut, Rhode Island, Massachusetts, New York, New

Jersey, and New Hampshire.

11According to Census Bureau data, the median household income in the northeastern region of the

United States was $39,368 in 1996.

Page 4 GAO/GGD-98-176 Live Loan Checks
B-279852 

meet minimum requirements set by proprietary risk and bankruptcy

models,12 according to Fleet officials. The borrower’s average debt

utilization—that is, the proportion of available credit limits actually used

in unsecured debt on current revolving credit sources—was 29 percent,

which the bank believes estimates the borrower’s propensity to use credit.

Also, borrowers had no prior record of bankruptcy, foreclosure, tax liens,

or garnishments.13 According to AFSA, its members who offer live loan

check programs reported that borrowers extended live loan check offers

are generally between 35 and 50 years of age with income levels between

$35,000 and $55,000.14

Disclosure Was Made to

Borrowers of Live Loan

Checks

Interviews with lenders, bank regulators, and the Federal Trade

Commission (FTC), which is responsible for, among other things, fostering

free and fair business competition and preventing monopolies and

activities in restraint of trade, revealed few complaints that live loan

checks terms were not disclosed to borrowers. According to lenders,

disclosure requirements are intended to protect the borrower and the

lender. Office of the Comptroller of the Currency (OCC) officials consider

live loan checks to be like any other small consumer loans in needing to

meet Truth In Lending Act15 requirements ensuring that creditors disclose

credit terms and the cost of credit as an annual percentage rate (APR).

We spoke with lenders about the disclosure features of their live loan

check programs. Fleet and Chase officials provided us with copies of their

disclosure materials, which contained information that identified the loan

check as a loan and clearly specified the interest rate and the terms and

conditions of the loan. In the lenders’ solicitation materials, for example,

there were several statements such as, “this is a check for a loan” or “loan

check.” The interest rate, repayment terms, and other terms were

displayed. The live loan checks were labeled “non-transferable” and “for

deposit only” to help ensure that the customers would take the checks

directly to their own banks for deposit. Chase officials told us that, under

their policy, a customer is to be called by a Chase bank official when the

check is presented by the depository bank to Chase for payment, to ensure

that the intended person actually deposited the check.

12These models were developed to predict bankruptcy and to further reduce the bank’s risk.

13A garnishment is a court order to an employer to withhold all or part of an employee’s wages and

then send the money to the court or to a person who won a lawsuit against the employee.

14According to Census Bureau data, the median household income nationally was $35,492 in 1996.

15The Truth in Lending Act, 15 U.S.C. 1601 et seq. The act is implemented by the Federal Reserve

Board’s Regulation Z, 12 CFR part 226.

Page 5 GAO/GGD-98-176 Live Loan Checks
B-279852 

The Industry Has

Developed Voluntary

Standards for Live Loan

Checks

AFSA issued voluntary standards for live loan checks on September 17,

1997, and expanded them on October 29, 1997. According to an AFSA

official, the voluntary standards for live loan checks are intended to

provide extra protection for consumers. Bank officials told us that they

abide by the voluntary standards to avoid the risk of creating a negative

image of the live loan check program. AFSA voluntary standards are as

follows:

• Live loan checks sent by mail or other similar instruments offered by AFSA

members are to be negotiable up to 6 months after receipt. A lender’s

printed material accompanying the offer must advise the consumer to void

and destroy the instrument if it is not going to be negotiated.

• Live loan checks sent by mail must include the following disclosure: “This

is a solicitation for a loan—read the enclosed disclosures before signing

and cashing this check.”

• Solicitations are to be mailed in envelopes with no indication that a

negotiable instrument is inside. Envelopes are to be marked with

instructions informing the Postal Service not to forward the item if the

intended recipient is no longer at the address on the envelope.

• In the event a live loan check-by-mail offer is stolen or fraudulently

cashed, the intended recipient is to have no liability for the loan obligation.

• In order to deter theft or forgery, a consumer is to be asked to complete a

confirmation statement provided by the creditor.

Major Participants

Offering Live Loan

Check Programs

Public and private sector officials told us that, while there was no

comprehensive list of institutions with live loan check programs, several

institutions were known to have offered such programs. Banks included

Fleet in Boston, Massachusetts; Chase Manhattan Bank in New York, New

York; Signet Bank in Richmond, Virginia; First USA in Wilmington,

Delaware; and BancOne Corporation in Columbus, Ohio.16 Nonbanks

included Capital One in Falls Church, Virginia, and Beneficial Corporation

in Wilmington, Delaware.17 First Chicago NBD had conducted test

marketing of live loan checks; a First Chicago official told us that the bank

discontinued the program because the level of loss in a pilot program was

not acceptable.

16On April 13, 1998, BancOne and First Chicago NBD announced a merger that is expected to be

completed during the fourth quarter of 1998. The new headquarters will be in Chicago.

17On April 7, 1998, Household International and Beneficial Corporation announced a merger agreement

that is expected to be completed in the third quarter of 1998.

Page 6 GAO/GGD-98-176 Live Loan Checks
B-279852 

Regulators and industry officials we interviewed also told us that no

comprehensive data show the volume of live loan check activity. These

officials also believed that it would be difficult for nonregulators to

compile such industrywide information because individual financial

institutions might be reluctant to release their proprietary data.

Although comprehensive industry data were not available, Fleet officials

provided us with information on Fleet’s live loan check program history.

(See table 1.)

Table 1: Fleet’s Live Loan Check

Program History Showing the Volume

of Live Loan Check Activity for the

Period 1995 Through March 1998

Year

Number of

live loan

checks

mailed

Percent of

solicited potential

borrowers who

were Fleet

customers

Number of

loan

acceptances

Loan amount

(millions of

dollars)a

1995b 50,000 100 8,000 $30

1996c 2,100,000 60 94,000 $400

1997 2,200,000 25 53,000 $250

1998 (through

March) 1,500,000 8 N/A N/A

Total 5,850,000 155,000 $680

Legend:

N/A = not available.

aThese figures are estimates.

bNineteen ninety-five was a test year.

cIn 1996, most of the live loan checks were sent to Fleet customers. The 40 percent sent to

non-Fleet customers were in the New England area, where Fleet officials said that consumers

could recognize Fleet’s name.

Source: Fleet Bank.

Although a similar number of checks were mailed in 1997 as in 1996, Fleet

experienced far fewer acceptances in 1997 compared with 1996. Fleet

officials said that the decline in acceptances occurred because in 1997 the

potential borrowers were primarily non-Fleet customers, who were less

likely to recognize Fleet’s name.

Page 7 GAO/GGD-98-176 Live Loan Checks
B-279852 

Benefits and Risks

Are Associated With

Live Loan Checks for

Both Borrowers and

Lenders

Public and private sector officials identified some benefits and risks

associated with live loan checks for both borrowers and lenders. In

general, the benefit for borrowers was the ease of obtaining the loan; the

risks to a borrower were comparable to those for other unsecured loans.

The Consumer Federation of America (CFA) told us that these loans could

compound problems caused by high consumer debt. For lenders, the loans

were often seen as profitable, with manageable risks. However, limited

data exist on the losses associated with live loan checks. Fraud did not

appear to be a widespread problem, although there was some concern

among industry officials about how a potential borrower might be

inconvenienced by fraud. First Chicago, however, discontinued making the

loans because the losses during a pilot program were “not acceptable.”

Borrowers Experienced

Benefits and Risks With

Live Loan Checks

In the view of lenders, borrowers enjoyed benefits and risks comparable

to those associated with conventionally marketed unsecured loans.

Borrowers accepted unsecured live loan checks at identical or lower

interest rates than the recipient would receive at a local loan office of the

lender. These loans had predictable, fixed monthly repayment terms of 48

to 60 months. According to lenders, borrowers experience little risk

beyond that normally associated with a loan because they are protected

against all liability from fraud or misuse.

Some public and private sector officials said that live loan checks could

potentially increase the possibility of default and bankruptcy if the

borrower misused credit by running up credit card balances. The

executive director of CFA said that live loan checks would only compound

the problems created by the abundance of unsecured, high-cost credit card

debt. Two lenders, however, said that there was no evidence to show that

borrowers would file for bankruptcy quicker as a result of accepting live

loan checks instead of using credit cards.

To date, it does not appear that many potential borrowers have been

exposed to the risk of fraudulently cashed loan checks. Lenders we spoke

with told us that the bank does not hold a consumer responsible if the

check mailed to that consumer is deposited or forged by another

individual. For example, Chase officials told us that, in the event that a live

loan check were stolen, the intended recipient would not be charged if he

or she signed an affidavit stating that the check had not been cashed by

him or her.

Page 8 GAO/GGD-98-176 Live Loan Checks
B-279852 

AFSA officials said that state and federal laws shield consumers from

liability related to live loan checks and that lenders’ credit selection

practices help reduce the rate of fraud. AFSA reported that the actual fraud

on live loan checks has been extremely low, less than one-tenth of one

percent of total mailings. AFSA believes that its voluntary standards ensure

minimum inconvenience to the consumer in the event that a check is not

cashed by the intended consumer.

Public and private sector officials have not seen large levels of fraud

involving live loan checks. OCC had no reported cases of fraudulent acts of

cashing a live loan check. Federal Reserve officials said they do not

believe that there is a significant problem with losses associated with live

loan checks. Federal Reserve officials noted that the primary reason for

the low rate of fraud is that rules governing check cashing practices act to

deter fraud. The recipient’s rights in the case of a forged endorsement are

generally governed by state law. Articles 3 and 4 of the Uniform

Commercial Code have been adopted in almost every state and determine

check negotiation procedures and liability for invalid checks. FTC and

Federal Reserve officials said that they had not received many complaints

about live loan checks that involved theft and fraud issues over a 2-year

period. The executive director of CFA testified, however, that the consumer

may experience considerable inconvenience if the live loan check is

cashed by someone other than the intended recipient, and believed that a

consumer should not experience any inconvenience if fraud occurs.

Lenders Using Live Loan

Checks Said They

Experienced Benefits and

Risks and Absorbed All

Fraudulent Losses

Fleet and Chase officials told us that their live loan check programs met

corporate profitability requirements and expanded their lines of credit and

their loan business. According to bank officials, live loan check programs

are attractive because they enable lenders to provide a broader range of

consumer loan products.

Lenders viewed live loan checks as a convenient means of delivering a

fixed rate, closed ended, unsecured loan product to a consumer. Fleet

officials said that live loan checks were moderately profitable loans. They

said that the results of these loans were provided monthly to senior

management to assess the results against expectations. Chase officials

said that a benefit of the bank’s loan check program was that the net

interest margin for live loan checks was higher than that for mortgage

lending. Chase officials told us that prepayment rates for live loan checks

are lower than those for mortgages. When interest rates decline, lower

payments help cash flows remain more stable, which helps Chase to better

Page 9 GAO/GGD-98-176 Live Loan Checks
B-279852 

manage its loan portfolio. In contrast, a decline in interest rates generally

results in a rise in prepayments of some other loans. Chase officials also

said that, by using good underwriting practices, they were able to manage

credit risk.

With regard to cases involving fraud, both lenders and bank regulatory

agency officials said that lenders are to absorb all losses. With 155,000

loans accepted between 1995 and 1997, for example, Fleet reported 68

confirmed cases of fraud. Generally, in these cases, an unauthorized

household member cashed the check. In order to prevent fraud, Fleet

required that the borrower access funds only by depositing a check into a

personal bank account. Once the live loan check was cleared, Fleet

created an installment loan for the borrower. To reduce the risk of fraud,

Fleet’s live loan check offers were only valid for 6 weeks.

Federal bank regulators do not have any special supervisory programs for

live loan checks. As noted earlier, OCC officials said that they review these

loans in the same way as they do other small consumer loans. Fleet

officials told us that monthly reports on these loans, which are distributed

to senior Fleet management, are also provided to OCC, Fleet’s regulator.

Federal Reserve examiners do not specifically monitor live loan check

activities at Federal Reserve-regulated institutions. As part of their safety

and soundness examinations, Federal Reserve examiners are to review

risk models or other risk management systems to assess whether banks

practice prudent behavior in their lending.

Little Data Available to

Identify Losses Associated

With Live Loan Checks

Federal regulatory officials told us that industrywide live loan check

activities are not tracked specifically. While Chase officials believed it was

too soon to estimate their losses on live loan checks, we received data

from Fleet concerning loss rates for its live loan check program.

In 1996 and 1997, according to Fleet officials, the bank’s loss rates on live

loan checks were lower than the credit card industry national averages.

Using year-end balances, in 1996, Fleet said, it experienced a 1 percent

loss rate compared to 5.96 percent in the credit card industry. In 1997,

Fleet experienced a loss rate of 4.20 percent compared to 6.04 percent in

the credit card industry. Fleet projected its 1998 live loan check losses to

be similar to the credit card industry’s at 5 percent. Fleet officials said that

they had set aside adequate reserves to cover anticipated losses. Fleet

officials explained that the reason for the reported loss increase for live

loan checks from 1996 to 1997 is that, typically, there are not many losses

Page 10 GAO/GGD-98-176 Live Loan Checks
B-279852 

in the early years with a new loan product, and that Fleet was more

cautious in marketing live loan checks. In the first year, 1995, Fleet

marketed all of its live loan checks to its bank customers. According to

Fleet officials, as the loans resulting from their live loan checks begin to

mature, losses could increase.

A First Chicago official told us that the bank discontinued its live loan

check program because the level of loss was not acceptable. First Chicago

conducted a live loan check pilot program in the summer of 1995 to

determine whether offering immediate access to funds via checks would

increase the likelihood that consumers would borrow money. The actual

loss rate was not disclosed to us.

Scope and

Methodology

To determine the characteristics of live loan checks, we gathered

information on various aspects of individual loans, as well as on the

average live loan check profile and the average borrower’s profile. To do

this, we interviewed officials representing three live loan check lending

institutions, an industry association, and a rating agency. We also reviewed

publicly available information, including published articles that reported

such characteristics. Although we did not independently verify these—or

any—industry data, we corroborated evidence with other independent

sources whenever possible.

To identify the major organizations that mail live loan checks, we

interviewed public and private sector officials. We selected officials to talk

to, in part, on the basis of information obtained from other industry

sources. For example, we talked with officials at Fleet and Chase. In

addition, we spoke with First Chicago officials about whether a live loan

check program existed at that institution because officials of other banks

had informed us that this institution had cancelled its live loan check

program. Moreover, we conducted a literature search and reviewed

selected articles that reported on live loan check lenders and their

activities. We also spoke to officials representing federal banking and

thrift regulatory agencies.

We obtained Fleet’s volume of live loan check lending in 1995, 1996, and

1997 and the expected volume in 1998 by interviewing Fleet officials; other

lenders were not willing to provide volume data. We attempted to identify

comprehensive, industrywide data for the volume of live loan checks by

talking with officials representing an industry association, a consumer

advocacy group, a rating agency, federal banking and thrift regulatory

Page 11 GAO/GGD-98-176 Live Loan Checks
B-279852 

agencies, and two investment banks. In addition, we contacted officials

representing another lender to corroborate information and to obtain

additional volume data.

To identify the benefits and risks of live loan checks for borrowers and

lenders, we interviewed officials representing federal regulatory agencies

and representatives from lending institutions, industry associations, and

one rating agency. We reviewed articles and studies that reported benefits

and risks associated with live loan check lending. We interviewed public

and private sector officials, and reviewed selected federal and state

regulations and laws, to gain an understanding of lender protection laws

relevant to live loan checks. We also spoke with banking officials about

losses associated with live loan checks.

As agreed with your office, unless you announce the contents of this

report earlier, we plan no further distribution until 30 days after the date

of this letter. At that time, we will send copies of this report to the Ranking

Minority Member of your Subcommittee, the Chairmen and Ranking

Minority Members of other congressional committees with jurisdiction

over finanical issues, the Chairman of the Board of Governors of the

Federal Reserve System, the Comptroller of the Currency, the Director of

the Office of Thrift Supervision, and other interested parties. We will also

make copies available to others upon request.

This report was prepared under the direction of James M. McDermott,

Assistant Director, Financial Institutions and Markets Issues. Major

contributors include Edwin J. Lane, Evaluator-in-Charge; Mitchell B.

Rachlis, Senior Economist; and Becky K. Kennedy, Senior Evaluator. If

you have any questions about this report, please call me on (202) 512-8678.

Sincerely yours,

Susan S. Westin

Associate Director, Financial Institutions

 and Markets Issues

(233559) Page 12 GAO/GGD-98-176 Live Loan Checks
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