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#2118347 - 02/15/17 05:32 PM Reg O Exec Officer reporting
T42 Offline
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Joined: Feb 2014
Posts: 51
Illinois
In reviewing Reg O I am confused about Executive Officer reporting. I understand that our bank can't lend over $100K to them except for children's education or their primary residence. The part that confuses me is that at our option the loan may "become due and payable at any time that the officer is indebted to any other bank or banks in aggregate amount greater than" previously stated.

Yes we have a due and payable caveat. But, are EO's required to report loans with other banks to the board? (besides loans secured by stock in our bank).

For instance, if a EO is a farmer and buys ground with a $400,000 loan at another bank - does that need to be reported for Reg O purposes to our board? Also, is it allowable under Reg O? Or does the "in no event more than $100,000" apply?
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Lending Compliance
#2118357 - 02/15/17 06:11 PM Re: Reg O Exec Officer reporting T42
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
How you choose to enforce that provision is up to you. Outside of reporting bank stock loans and loans from correspondent banks, there no longer is a regulatory EO reporting mechanism back to the bank for other loans. The $100,000 only applies to loans from your bank.
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#2118361 - 02/15/17 06:30 PM Re: Reg O Exec Officer reporting rlcarey
T42 Offline
Member
Joined: Feb 2014
Posts: 51
Illinois
Can you direct me to the information you sited that there is "no longer is a regulatory EO reporting mechanism"? Thanks so much!
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"Whatever you do, work at it with all your heart, as working for the Lord, not for human masters" Colossians 3:23

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#2118362 - 02/15/17 06:52 PM Re: Reg O Exec Officer reporting T42
T42 Offline
Member
Joined: Feb 2014
Posts: 51
Illinois
Perhaps https://www.federalreserve.gov/newsevents/press/bcreg/bcreg20070529a1.pdf the Financial Services Regulatory Relief Act o of 2006?
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"Whatever you do, work at it with all your heart, as working for the Lord, not for human masters" Colossians 3:23

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#2118371 - 02/15/17 07:18 PM Re: Reg O Exec Officer reporting T42
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
That would be it. smile
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