Hi,
One of our Board of Directors recently passed away. He had a Commercial loan & a mortgage with us. Do we still report those totals in our loans to Officers for Reg O purposes?
What is the criteria? Do we continue to report it until it's paid off or refinanced? Or can we just stop including them?

Thanks,
Edie

Under certain section of the reg there are records requirements:
215.8 Records of Member Banks
The bank must maintain records that identify each insider of the bank by conducting an annual survey. Alternative methods are permitted for identifying insiders of the bank’s affiliates. The bank must also specify the amount and terms of each extension of credit made to any insider.

I would imagine that your bank has already identified in their annual survey him as an insider. I would also believe that at the next board meeting it would be recognized that this individual is no longer a member of the board and therefore no longer an insider.