If an insider is an authorized signer on a commercial account (he is NOT the owner of the entity), and that account overdraws over $100,000, is this a Reg O violation?
No, even ODs on related entities are not covered by Reg O, but you need to understand why a director is an authorized signer and does he exercise control over that entity.
ODs can trigger approval requirements for credit if the entity must be combined. Additionally, poor management of related entities is an issue.
Last edited by Kathleen B; 12/10/1412:55 PM.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com