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#2230020 - 01/31/20 04:09 PM Subject to Reg O? Tricky
ljones9 Offline
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Joined: Aug 2018
Posts: 19
Would these qualify as subject to Reg O?

Commercial loan #1 to an entity owned by a partnership with the director's spouse as a principal, guaranteed by the director's spouse and a Spousal Access Trust.
Commercial loan #2 to an entity owned by the director's spouse and the same partnership, guaranteed by the director's spouse and a Spousal Access Trust.

The director is neither a borrower or guarantor on either loan. I know that the general question to ask is whether the director would receive any tangible net benefit from the loans. Even if she's a beneficiary of the Spousal Access Trust, does that qualify as net tangible benefit? It seems a stretch to me, but can't get this wrong. We are not in a community property state.

Any help would be much appreciated.

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#2230089 - 02/01/20 12:35 PM Re: Subject to Reg O? Tricky ljones9
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,216
Galveston, TX
Who is the Grantor on the Spousal Access Trust.
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