Skip to content
BOL Conferences
Thread Options
#1527046 - 03/25/11 02:45 PM Reg O - Related Interest?
MEB Offline
Member
Joined: Oct 2006
Posts: 51
Kentucky
Several of our directors have personal checking accounts that have "farm account" or "cattle account" in the title. Overdrafts have been paid on these accounts. Management claims that these accounts are for related interests of the directors. I do not believe that these accounts are exempt under 215.4(e) as related interests because there is no company/business entity. During a recent exam, no violations were cited regarding the overdrafts being paid on these accounts. Am I being too critical or did we get lucky that the examiners did not identify these?

Return to Top
Lending Compliance
#1527051 - 03/25/11 02:49 PM Re: Reg O - Related Interest? MEB
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You got lucky if the accounts are in the directors' own names.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top

Moderator:  Andy_Z