Not actual names....

John is an exec officer. Mark is a customer. Mark has a loan issued in his name; John is marked as a Grantor on the loan and did not receive any of the loan proceeds. They do not share the same home address. Our bank keeps a running tally on our execs, directors,... Should this loan be included in John's tally as a Reg O reportable loan?

I believe so, by 215.3(a)(7)"An extension of credit is making or renewing of any loan...and includes: Any other similar transaction as a result of which a person becomes obligated to pay money (or its equivalent) to a bank, whether the obligation arises directly or indirectly, or because of an endorsement on an obligation or otherwise, or by any means whatsoever." John is obligated to pay Mark's loan in the event that Mark defaults. I believe there is wording in the promissory notes to the effect that if Mark doesn't pay, the bank can go straight to John for collection, bypassing Mark. So it should be included in John's Reg O total as a reportable loan.

But John is a Grantor, not Guarantor.

So the collateral that John has put up is at risk, but not anything else of Johns.

I don't know if this makes a difference in the interpretation but it might.

Could it be that John has enlisted the help of Mark to evade John having a Reg O loan? Hmmm! Interesting!

Thank you SLU Voice and doyoucanoe for your answers. Raidersn, I appreciate the thought and it may well be a usefull thought later on (I certainly hope not). But I don't think it has any bearing here. This is a very very small dollar loan and John is no where within sight of exceeding the Reg O lending limitations.