For Reg O purposes, are accounts in the insiders name with ownership as custodian, trustee, authorized signer subject to the overdraft provisions of Reg O?

For example a director is "trustee" on a number of retail DDA accounts in the name of trusts - his own trust, parents trust, sibling trusts. Should any of these accounts be reviewed for overdrafts for Reg O pubposes?

If they are a beneficiary - I believe so. If not a beneficiary, the trust may still be a related interest, but that would not impact the overdraft provisions.

Letting a trust account go into overdraft is usually a breach of fiduciary responsibilities, unless under specific circumstances.

Can I dredge this one back up for further discussion?

If an executive officer is an "authorized signer" on an account, would Reg O overdraft rules apply? By "authorized signer," I mean a convenience signer. In other words, the executive officer is not an owner of the account. He or she is allowed to authorize transactions on the account as a convenience to the owner....which means that he or she can legally do just about anything in connection with the account. But the owner can terminate the arrangement at any time and the arrangement automatically termininates upon death.

No. Related interests do not apply to this section.

3\ This prohibition does not apply to the payment by a member bank of an overdraft of a principal shareholder of the member bank, unless the principal shareholder is also an executive officer or director. This prohibition also does not apply to the payment by a member bank of an overdraft of a related interest of an executive officer, director, or principal shareholder of the member bank or executive officer, director, or principal shareholder of its affiliates.

Pardon my ignorance, but you're quoting from where?

Nevermind..........I see that it's a footnote. Thanx much. I now feel dumb.

Soooo.......if an OD is paid on a "related interest" as in my example above, it's not a violation of Reg O because the overdraft rules do not apply to related interests. But must the OD be counted with extensions of credit made to the executive officer?

Hey Swiggles . . . years later, but "Yes," my understanding is it would still need to be dealt with from the extension of credit standpoint.