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.
Offering Reg O Insider A Higher Rate on Deposit?
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?
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.
Who is an "insider" for purposes of Regulation O?
Is there a Reg. O requirement that the related interest reporting for insiders must be completed by January 31st of each year?
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?
Is a Loan to an Executive Officer for the purchase of an Investment residential property for his daughter a Reg. O violation?
Can you have the demand feature for an executive officer on an open end line of credit?
Reg O - Directors (not Executive officers). Are primary residences subject to Reg O reporting for directors? Are there specifics to when they are or not be be reported such as on the mortgage system, loan side, 2nd lien or purpose like Executive officers?