07/16/2023
An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee.
I don't know which Reg takes precedence. The account is overdrawn less than $100.
05/22/2022
What department is best to manage employee account overdrafts?
12/20/2020
Can a bank require employees to have an account and services so that they can help customers with functionality? We do not require them to have their payroll deposited at our institution.
06/17/2018
We are about to implement a risk based billpay model in online banking. Our billpay vendor will make the payments on the customers' behalf, and then send us a file that we will post to the customers' accounts. If there are insufficient funds to cover any of the billpays, we will need to attempt to collect the amount from the customer due to the fact the funds have already been sent. Would this be considered an overdraft program or an extension of credit? Would there be any Reg O concerns associated with this process considering a Director could initiate a billpay that overdaws their account and if it is considered an extension of credit it may cause a Reg O issue. I do not believe this is governed by overdraft regulations and would not be considered an extension of credit.
01/07/2018
Offering Reg O Insider A Higher Rate on Deposit?
12/24/2017
As it pertains to Reg O and overdraft monitoring: Are business DDA accounts for which directors are signers to be included in the overdraft monitoring process?
04/23/2017
We have a director who is a guarantor on a loan for someone else. It is not a related entity. For Reg. O aggregate debt purposes, would this loan need to be included? This loan is at our legal lending limit, but the director has no direct debt. The issue is that he has had some inadvertent overdrafts recently on his related entity, and we want to make sure that paying the overdraft doesn't violate Reg. O.
02/26/2017
Who is an "insider" for purposes of Regulation O?
11/20/2016
Is there a Reg. O requirement that the related interest reporting for insiders must be completed by January 31st of each year?
02/09/2015
We have been told that according to Reg O, we must have a financial statement completed annually for any shareholder who holds 10.9% or more in our stock. I have not been able to find this requirement in Reg O. The shareholder is not a director of the bank. Could this be an SEC requirement?