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#2184511 - 07/09/18 03:47 PM Regulation O
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
We have a loan to a Executive Officer that we are going to release a vehicle title and will still retain the other title. If we release the title, would that trigger anything for Reg O purposes? The loan is grandfathered in as it was originated before the Executive Officer status so if it triggers anything it would be outside his $100K limit.

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Lending Compliance
#2184617 - 07/09/18 08:05 PM Re: Regulation O ahkcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
If you touch a loan, it is no longer grandfathered. So the question is, would you do this for everyone else and do they have more than $100K outstanding?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2184644 - 07/09/18 08:43 PM Re: Regulation O ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
Yes, we would and have done this for other borrowers. They have paid down sufficient to release the collateral and yes, there they are at the $100K limit due to an LLC loan. All current loans are grandfathered in as they were done prior to the EO status.

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#2184665 - 07/10/18 05:50 AM Re: Regulation O ahkcompliance
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
All current loans may be grandfathered, but once you touch one of them, then that grandfathering goes away. It is the total relationship that is grandfathered, it is not loan by loan.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2184713 - 07/10/18 02:38 PM Re: Regulation O ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
Thanks Randy. We were sure if just releasing collateral would trigger anything or not. We will not be doing any modification of terms, etc.

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#2184856 - 07/11/18 01:01 PM Re: Regulation O ahkcompliance
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
How is releasing the title not a modification of the loan terms? The collateral requirement is a loan term.
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The opinions expressed are mine and they are not to be taken as legal advice.

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