Skip to content
BOL Conferences
Thread Options
#2150319 - 10/18/17 06:24 PM Reg O New Executive Officer
Tryin2Comply Offline
Member
Joined: Aug 2014
Posts: 76
We have a newly appointed Executive Officer. She had previous loans with the bank. The demand feature is not in either of her loans (because she was not an executive officer at origination). Does she need to sign and addendum to include the demand feature?

Return to Top
Lending Compliance
#2150336 - 10/18/17 07:17 PM Re: Reg O New Executive Officer Tryin2Comply
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
These loans would be grandfathered until a triggering event occurred such as getting a new loan, renewing or extending the existing loan, an overdraft being paid, etc.

https://www.occ.gov/static/interpretations-and-precedents/apr08/int1096.pdf
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top

Moderator:  Andy_Z