PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 11

                                         11                                           

          Commercial Loans                                                            

               Respondent disallowed deductions related to the origination            
          of commercial loans made by FNBP.  No adjustments for commercial            
          loan origination costs were made with respect to UFSB.9                     
               FNBP employees with responsibility for commercial products             
          and services met with prospective commercial borrowers to explain           
          the available loan products.  Where the prospective borrower                
          wished to apply for a loan, the responsible employee obtained               
          information needed to complete a loan application.  FNBP employed           
          as many as nine commercial loan officers to handle its larger               
          business customers and to develop new commercial business.  Some            
          FNBP branch managers also acted as commercial loan officers.                
          Commercial loan officers at FNBP typically had 25 to 30 clients             
          and spent approximately 85 percent of their time dealing with               
          existing clients and about 15 percent of their time with                    
          prospective clients.  FNBP commercial loan officers visited                 
          existing clients on a quarterly basis at which time they                    
          discussed, among other things, the client's financial statements            
          and overall financial condition.                                            


               Commercial loan applications identified the prospective                
          borrower and described the prospective borrower's income, assets,           
          and liabilities; the purpose of the loan; and other data                    


               9There is no explanation for this, and the parties do not              
          base any of their arguments on this disparity.                              


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