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loan was 12.95 percent, and the interest rate on the original
Pempire $1,830,000 CD was 11.8 percent. The promissory note
documenting the original UB $1,830,000 loan provided that the
interest on that loan was payable by BOT semiannually.
Union Bank renewed the original UB $1,830,000 loan on three
occasions for periods that ended on the following dates: October
10, 1985 (UB $1,830,000 loan first renewal), April 10, 1986 (UB
$1,830,000 loan second renewal), and July 10, 1986 (UB $1,830,000
loan final renewal). To document each of the first two renewals
of the original UB $1,830,000 loan, petitioner signed on behalf
of BOT a promissory note that was made payable to Union Bank and
that was in the same amount as that loan. The interest rate on
all three renewals of the original UB $1,830,000 loan was set at
1.15 percent above the interest rate on the renewals of the
original Pempire $1,830,000 CD (which ranged between 6.6 and 7.9
percent). The interest on the UB $1,830,000 loan first renewal
was payable by BOT at that loan's maturity. The interest on the
UB $1,830,000 loan second and final renewals was payable by BOT
monthly.
When the original Pempire $1,830,000 CD matured on July 15,
1985, it was renewed 10 times for successive periods consisting
of three one-month renewals, one three-month renewal, and six
one-month renewals. The 10th and final renewal of that certifi-
cate matured on July 10, 1986, the same date on which the final
renewal of the original UB $1,830,000 loan was due. The dates on
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