Many bank officers serve on Boards of Directors or officiate in some capacity with various groups, and not entirely for philanthropic purposes, but as PR and Busines Development opportunities. I doubt that applies to the church, but if the officer has mearly brought into the bank a good piece of business, presents it to the loan committee who have full disclosure of the officers involvement, the officer is not part on the credit decision, the church did not receive any preference in the approval or rates and terms and everything is documented to these facts, then I don't believe its a Reg O violation.
My belief is that a violation based purely on a "power to exercise a controlling influence" alone is to literal of an interpretation of the reg. If that standard was applied without including all other facts then we have a hugh Reg O problem in this country.
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