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#2141685 - 08/11/17 02:40 PM Reg O Question - New Chairman of the Board
MTBDeb Offline
Junior Member
Joined: Oct 2016
Posts: 42
I haven't delved into amounts outstanding yet, but one of my banks just got a new Chairman of the Board, which means we have a new Executive Officer. Where should I go for commentary on how to proceed with outstanding loans to himself and his related interests?

I'm assuming we will just back him into compliance by having him move any loans that aren't education or primary residence related, but if there is an official way to handle this I would really like to know about it. smile All advice and assistance welcome as well.

Thank you!!!

Deb

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Lending Compliance
#2141687 - 08/11/17 02:43 PM Re: Reg O Question - New Chairman of the Board MTBDeb
MTBDeb Offline
Junior Member
Joined: Oct 2016
Posts: 42
Nevermind, I found it. Is it Friday yet?

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#2141700 - 08/11/17 03:22 PM Re: Reg O Question - New Chairman of the Board MTBDeb
MTBDeb Offline
Junior Member
Joined: Oct 2016
Posts: 42
The commentary to Reg O makes it clear that loans done prior to the appointment to COB are just that, there's' nothing really to do except document the loans and keep track of when, during the course of paydowns, his aggregates become compliant with limitations. However, the commentary says nothing about unfunded committments. This person owns a company that has outstanding, but unfunded, and renewable LOCs to the State of Colorado. Any opinions on whether or not unfunded committements fall under this, "new appointment" exception to Regulation O lending limits to Executive Officers?

Thanks!

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#2141702 - 08/11/17 03:33 PM Re: Reg O Question - New Chairman of the Board MTBDeb
fmissle Offline
Platinum Poster
Joined: Jul 2007
Posts: 989
Pac NW
My opinion is that if the LOC (I'm assuming letters of credit) were issued prior to the appointment, they're okay at this time. I don't think, if they exceed the limits, that you'd be able to renew them.

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#2141709 - 08/11/17 03:47 PM Re: Reg O Question - New Chairman of the Board MTBDeb
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,294
Galveston, TX
Correct - no new loans or renewals until under the limits.
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