July 3, 2001

Conrad Schlund, Compliance Manager
Suffolk Federal Credit Union
3681 Horseblock Road
P.O. Box 9005
Medford, New York   11763

Re:  Maturities on Boat Loans.

Dear Mr. Schlund:

You have asked us if a boat may be considered a mobile home and qualify for a 20-year loan maturity.  12 C.F.R. §701.21(f)(1).  Previously, we stated that, if a federal credit union loan on a recreational vehicle or house trailer is secured by a first lien and meets the requirements for a home mortgage interest deduction, the loan qualifies as a mobile home loan for the 20-year maturity limit.  This is discussed in the enclosed letter from me to Gwen Baker, dated June 4, 2001.  Like recreational vehicles and house trailers, we conclude that a boat may be considered a mobile home for loan maturity purposes.  If a boat loan is secured by a first lien and qualifies for the home mortgage interest deduction, as discussed in my letter to Ms. Baker, then we believe that it likewise qualifies as a mobile home loan with a 20-year maturity limit. 

                                                                        Sincerely,

 

                                                                        Sheila A. Albin
                                                                        Associate General Counsel 

OGC/PMP:bhs
SSIC 3500
01-0640

Enclosure