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#1450593 - 10/01/10 02:22 PM Reg. O and Directors
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New England
When calculating the lending limits for a Director, can we exclude any loans that were extended prior to them being appointed? I know that there is an exception for Executive Officers, but I can't seem to find the same exception for Directors.

Thanks!
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Lending Compliance
#1451046 - 10/01/10 10:03 PM Re: Reg. O and Directors Book Nerd
rlcarey Online
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rlcarey
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Galveston, TX
As far as terms and conditions, etc. Yes. As far as reporting, no.

The indivudual lending limits for directors are no different than anyone elses.

Are you talking aggegate lending limits??
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#1451138 - 10/04/10 01:22 PM Re: Reg. O and Directors rlcarey
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New England
Yes, I'm asking about the aggregate lending limits. Do we calculate all outstanding loans, or just the loans extended after they become a director?
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#1451911 - 10/05/10 06:42 PM Re: Reg. O and Directors Book Nerd
rlcarey Online
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rlcarey
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Galveston, TX
I have not seen a specific ruling, but it would probably be treated like all the other grandfather provisions. The current over the limit situation is not a factor, however, no new actions can be taken without bringing the non-conforming situation into confomance. This would mean no new director loans to any director until you were back under the limit. A call to your regulator may be in order to get a current opinion.
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