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Latest Compliance - Lending Limit Topics

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?

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?

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OCC Lending Limits

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Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Reg E Fraud- EFT Claim for Cash App

07/25/2021

During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)

Reg E Telephone Transfers/Transactions

07/25/2021

I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.

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