We had a new executive officer earlier in 2019. This individual already had existing loans with the bank. Are we required to have the demand feature for these existing loans, or only for new loans while he is an active EO? My instinct is that we do not have to have them sign it, due to timing.

Thanks!

Existing loans are grandfathered unless refinanced or renewed.

We have an existing employee that was recently named a Reg O Executive Officer, who has existing debt that exceeds $100,000 (that does not meet any of the exemptions). How do we need to handle this?

Thanks!

Those loans are grandfathered. They just cannot do anything new until they get under the limit - no refinances, extensions, etc.