Banking Interpretations


September 14, 2006


Re: Aircraft Loans

Dear [---]

Your letter dated April 4, 2006 to Sara Kelsey, Deputy Superintendent and Counsel, New York State Banking Department (the "Department"), has been referred to me for response.  In your letter you asked whether [---] Financing, Inc. or [---] Capital Solutions (the "Company") needs a license from the State of New York to make non-consumer aircraft loans. The answer is no.

Because aircraft loans or any time sale financing arrangement for aircraft would be for business rather than consumer purposes, a license as a licensed lender under Article IX of the Banking Law or a sales finance company under Article XI- B of the Banking Law, respectively, would not be required

I trust the foregoing is responsive to your inquiry.

Very truly yours,

Alan M. Weinberg
Assistant Counsel