Is there a rule (written or general) that the Reg O Officer can't be an executive officer? It just seemed like a conflict of interest to me. Any thoughts? How do other banks handle that?
Banks handle this in numerous ways. Just make sure all ODs are treated appropriately. That is where you could run into a conflict by someone approving their own ODs.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com