Skip to content
BOL Conferences
Thread Options
#1764703 - 12/06/12 06:53 PM Reg O issues?
Piano Man Offline
Gold Star
Piano Man
Joined: Mar 2004
Posts: 442
Down South
Director A hires Company B to complete work for him. Company B has very little to no other income stream to repay debt other than completion of construction project for Director A. Are there any Reg O issues with this request? I think I am over thinking Reg O requirements.
_________________________
Love so amazing, so divine; Demands my soul, my life, my all.

Return to Top
Lending Compliance
#1764741 - 12/06/12 07:14 PM Re: Reg O issues? Piano Man
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
I'm not sure what Reg O would have to do with Dir A hiriing Co B to do whatever work they do for him? Can you be more specfic about what your concerns are?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#1764856 - 12/06/12 09:18 PM Re: Reg O issues? Piano Man
Piano Man Offline
Gold Star
Piano Man
Joined: Mar 2004
Posts: 442
Down South
I think what has me curious is the loan is being repaid from our directors funds. The borrower has no other income except what is coming from our director. Like I said, I really think I am WAY over thinking this.
_________________________
Love so amazing, so divine; Demands my soul, my life, my all.

Return to Top
#1764879 - 12/06/12 10:02 PM Re: Reg O issues? Piano Man
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Well... is the loan to finance the work to be done for the director? If so then you might have to look at this being a "straw" borrower for the director or is the director getting an economical benefit through this arrangement?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#1765080 - 12/07/12 03:16 PM Re: Reg O issues? Piano Man
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
"Company B has very little to no other income stream to repay debt other than completion of construction project for Director A."

How was the loan ever approved? Sounds like a misuse of position to me if the director influenced the decision and the borrower did not qualify under general credit underwriting guidelines.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z