Abe Lincoln is a director. He has disclosed 12 different related interests. One of those related interests, ABC Company, is OD. ABC Company or Abe Lincoln do not have exposure greater than $500,000, but if you add up the exposure of all 13 parties there is that exposure. Question - does the OD for ABC Company fall under Reg O OD requirements? Thank you.

does the OD for ABC Company fall under Reg O OD requirements?

No (see 215.4(e) Footnote 3), but if the director and all his related interests exceed the allowable exposure limits with your FI it would require prior approval because the OD would be an extension of credit (215.4(b)).