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#1747439 - 10/08/12 08:19 PM Reg O - Aggregate Extensions of Credit
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I'm feeling brain dead today. When calculating the aggregate amount of all extensions of credit to all executive officers, directors, principal shareholders, and their related interests, the exclusion of overdraft lines of credit of $5,000 or less have me tripped up.

1) When one executive officer has two ODLs, and together they aggregate to more than $5,000, do I include the full amount of both ODLs or only the amount over $5,000? I'm thinking it's only the amount over $5,000.

2) Does the exclusion apply to ODLs of related interests? The reference in 215(3)(b)(6) to 215(4)(e) has got me thinking that ODLs for related interests must be included when calculating the aggregate extensions of credit, regardless of the amount, since they are excluded from the overdraft prohibition. Would that mean that the entire amount of an ODL to a related interest should be included in the calculation of all loans to insiders?

Thank you for your help.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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Lending Compliance
#1747452 - 10/08/12 09:16 PM Re: Reg O - Aggregate Extensions of Credit Kelsey D
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,663
Galveston, TX
1) An EO only gets one dip at the bucket.

2) That would be correct. No exclusion for related interests.
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#1748883 - 10/12/12 03:11 PM Re: Reg O - Aggregate Extensions of Credit Kelsey D
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Thanks Randy. So if the EO's ODLs total $5,500, I should only report $500?
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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