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#1450593 - 10/01/10 02:22 PM Reg. O and Directors
Book Nerd Offline
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Book Nerd
Joined: Jun 2007
Posts: 447
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
Joined: Jul 2001
Posts: 83,360
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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Book Nerd
Joined: Jun 2007
Posts: 447
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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Sometimes the questions are complicated and the answers are simple. - Dr. Suess

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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
Joined: Jul 2001
Posts: 83,360
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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