Latest Compliance - Lending Limit Topics

Loan Policy Exception Management

01/22/2017

How do banks use technology to manage loan policy exceptions?

Reg O - Loan to Business Owned by Director's Wife

11/30/2009

Is a loan to a business owned by a director's wife subject to Reg O? The director provides no personal guarantee.

Reg O - Loans to Immediate Family

05/28/2007

Does Reg O apply to loans to immediate family members? For example, the spouse of an individual, the individual's minor children and any of the individual's children. If so, where in regulation does it state this?

Reg O - Readily Marketable Collateral

05/14/2007

Reg O - Individual Lending Limit, what is the definition of the term "readily marketable collateral" in relation to an insider's lending limit (the additional 10% of unimpaired capital and unimpaired surplus)? Is real estate with a valid appraisal considered "readily marketable collateral"?

Reg O - Single Insider Aggregate Lending Limit

05/01/2006

I need you to settle a dispute regarding Reg O. When doing the annual review of Reg O, and totaling the dollar amount of extensions of credit to determine an executive officer's "single insider aggregate lending limit," do you use the original amount of the loans or do you use the balance owing on the loans? (Excluding lines of credit on which you do use the original amount.) This is in regards to the $100,000 restrictive lending limits for executive officers. I say we should use the original amount of the loans and the CCO says we should use the balance owing as of the date of the review. Could you please clarify this for me?

Loan to spouse considered loan to EO?

01/09/2006

An executive officer's spouse obtains a loan to purchase property over $100k. The property is deeded to the spouse only, but the executive officer is required to sign the mortgage due to state real estate laws. Is the credit considered an extension of credit to the executive officer, since his signature was required on the mortgage in order to pledge the property to the note?

Insider Lending Limits & Mortgages

06/09/2003

Prior Board Approval under Reg O

01/06/2003

Our bank falls under the $500,000 prior board approval requirement for extensions of credit to an insider. If I understand Regulation O correctly, exceptions under general prohibitions only apply to the aggregate lending limit when the loan is secured by a CD. If a loan is made to an insider for more than $500,000 and is secured by a CD in our bank, is prior board approval required?