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.

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?

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.

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.

Thanks Randy. We were sure if just releasing collateral would trigger anything or not. We will not be doing any modification of terms, etc.

How is releasing the title not a modification of the loan terms? The collateral requirement is a loan term.