I know an extension of credit needs prior Board approval if the aggregate (including related interests) exceeds $500,000. Is that the only time an insider loan transaction is reported to the Board? We have been reporting extensions of credit after origination if the aggregate is less than $500,000, but that may be overkill. We also report overdrafts no matter what the amount.

Well, every extension of credit regardless of the amount to a EO must be reported to the board under 215.5(d)(1).

Other then that, there is no specific requirement. But a lot banks do periodically in some form or another, just to keep them informed of insider activities.

Question regarding Non-Executive Officer loans. Do these need to be reported to the board PRIOR to approval? Our policy includes Officers, but I believe regulations only require it for Executive Officer, Directors and their related interests. All employee loans are reviewed at the quarterly meeting after they are disbursed.

Whatever you do for employees that are non-Reg O insiders is either bank policy or potentially a State law issue.

Thank you, I appreciate your quick reply!