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#2073961 - 04/13/16 08:29 PM Reg O - Secured by CD or Money Market Acct
Joanna Offline
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Joined: Sep 2013
Posts: 102
Would Reg O apply if the loan was secured by a CD or a money market account?

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Lending Compliance
#2073967 - 04/13/16 08:45 PM Re: Reg O - Secured by CD or Money Market Acct Joanna
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
Absolutely. The only thing a dedicated interest in a deposit account accomplishes is getting you outside of some of the lending limits. Applicable requirements for terms and conditions, approvals, preapprovals, board reporting, call reporting, financial statements, etc. will all apply.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2073968 - 04/13/16 08:47 PM Re: Reg O - Secured by CD or Money Market Acct Joanna
Joanna Offline
100 Club
Joined: Sep 2013
Posts: 102
That is what I found also but wanted to make sure...another tenured executive officer said it would not apply. I am the "newbie" compliance officer so it can be difficult to say no.

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#2073978 - 04/13/16 09:10 PM Re: Reg O - Secured by CD or Money Market Acct Joanna
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
Been at this for 30+ years - so not a newbie and if you need support just print this thread smile

OK - 35+ years shocked
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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