2  For the purposes of this opinion, we are assuming that there are no facts requiring combination of the Existing Loan and the New Loan under either the direct benefit test or the common enterprise test set forth in 7 TAC §12.9. This opinion also assumes that there are no facts requiring application to the Existing Loan and the New Loan of the lending limit for corporate groups under 7 TAC §12.9(e). Under Subsection (e), the total of all loans or extensions of credit to members of a corporate group may not exceed 75% of the Bank's Tier 1 capital.