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#1360720 - 03/19/10 02:48 PM Reg. O Correspondent Debts
CompDat Offline
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When I look at the Federal Reserve summary of Reg. O it says that executive officers are still required to report debts to correspondent banks. But I cannot find this in the regulation. Am I going crazy?

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Lending Compliance
#1360758 - 03/19/10 03:14 PM Re: Reg. O Correspondent Debts CompDat
Sinatra Fan Offline
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New Jersey
No, you are not crazy. It's no longer in the reg.

Effective July 2, 2007, the FRB adopted amendments to Regulation O which eliminated the requirement that executive officers report loans from other banks to their board of directors, either upon obtaining the loan or on a annual basis. See Federal Register Volume 72, No. 105, Friday, June 1, 2007, Page 30471.

The final regulation does note that, "In light of the elimination of the statutory and regulatory reporting requirements associated with 12 U.S.C. 1972(2), a bank may select any reasonably prudent method to ensure compliance with the restrictions."
Management is doing things right; leadership is doing the right things. Peter Drucker

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#1361375 - 03/20/10 01:18 PM Re: Reg. O Correspondent Debts Sinatra Fan
rlcarey Offline
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Galveston, TX
Regulation O no longer requires reporting, but the Bank still needs to know about the relationships under a different part:

Part 349 of the FDIC Rules and Regulations requires that executive officers and principal shareholders report the terms and amounts of their indebtedness to correspondent banks to their respective boards of directors. The purpose of this regulation is to aid in the determination of preferential lending practices to executive officers, directors, and principal shareholders of a bank where a correspondent relationship exists.
The opinions expressed here should not be construed to be those of my employer:

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#1403277 - 06/14/10 05:57 PM Re: Reg. O Correspondent Debts rlcarey
Frank Ernest Offline
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Somewhere on a beach
In Randy's reply he refers to Part 349 of the FDIC Rules and Regulations. When I look at the Rules and Regulations it indicates that Part 349 is reserved. Should the reference be another part or has this part been removed?

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