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#112293 - 09/04/03 10:36 PM Reg O - New Twist
SJB Offline
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SJB
Joined: Jun 2002
Posts: 1,210
California
My understanding has been that an executive officer can refinance their purchase money loan and take cash out so long as they stay within the "general" $100,000 limit for the cash out and any other loans from the bank. Another compliance pro is telling me the home refinance can only be for purchase, maintenance or improvement and that the "cash out" part should be a separate home equity loan.
Doesn't seem like a reasonable interpretation to me but I have been wrong before!
Anyone else have some input on this?
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Lending Compliance
#112294 - 09/05/03 01:43 PM Re: Reg O - New Twist
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
You have to stay within the $100,000 "other" limit. Making the "other" portion a separate loan would make it easier to track extensions of credit subject to the limit, but there is no requirement that there be a separate extension of credit.

If you can keep track of the cash-out amount as an "other" purpose borrowing as part of the a refinance, I don't see a problem with that.
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