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#1096058 - 12/11/08 09:31 PM I feel stupid even asking, but here goes...
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
Regarding Reg O and the definition of "member bank". What type of bank isn't a member bank? Isn't every bank a member of the Federal Reserve System, regardless of their regulator, or regardless of whether they are a state or national bank? We all process payments in the same system, don't we(?).

Thanks for not laughing, (or for at least not telling me that you did!) grin

Deb

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#1096073 - 12/11/08 09:55 PM Re: I feel stupid even asking, but here goes... Wyogirl
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
Not every bank is a member of the Federal Reserve and only State banks are eligible. If you are a member bank then your regulator would be the Federal Reserve.
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#1096124 - 12/11/08 10:58 PM Re: I feel stupid even asking, but here goes... rlcarey
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
Wow, I guess I was waaaaay off base. So, if I've got a state chartered, FDIC bank telling me they don't have to follow the reporting requirements of reg O, are they correct? How is Reg O applicable to any bank that is not a "member" as defined in the reg?

Thanks a ton,

Deb

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#1096146 - 12/11/08 11:35 PM Re: I feel stupid even asking, but here goes... Wyogirl
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
Ok, I think I have it:

PART 337—UNSAFE AND UNSOUND BANKING PRACTICES (FDIC Rules and Regulations)

§ 337.3 Limits on extensions of credit to executive officers, directors, and principal shareholders of insured nonmember banks.

(a) With the exception of 12 CFR 215.5(b), 215.5(c)(3), 215.5(c)4, and 215.11, insured nonmember banks are subject to the restrictions contained in subpart A of Federal Reserve Board Regulation O (12 CFR Part 215, subpart A) to the same extent and to the same manner as though they were member banks.

Let me know if I'm still waaaay off base though. Thanks.

Deb

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#1096156 - 12/12/08 12:00 AM Re: I feel stupid even asking, but here goes... Wyogirl
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Yes, FDIC incorporates most (but not all) of Reg O in §337.

If I remember correctly, FDIC would allow a HELOC, but FED and OCC would not.

Al
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Opinions expressed are my own and not necessarily shared by my employer.

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#1096164 - 12/12/08 12:33 AM Re: I feel stupid even asking, but here goes... Al Miller
Andy_Z Online
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Andy_Z
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Each agency has very similar rules and even the regulators often refer to the lettered reg.

You can find the various agencies regs under their section of the legal binders.

OCC 1 - 99
FRB 200 - 299
FDIC 300 - 399
OTS 500 – 599
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