Help please... I'm struggling with understanding section 215.4(b)(3) of Regulation O and what this is really saying.
We have a million dollar line of credit which was extended to an insider for 24 months. The extension of credit received Board approval under 215(b)(2) as it exceeded $500,000. Since the line of credit was extended for 24 months, do we have to go back to the Board again in 14 months or can we just wait until the term of the loan expires and go back for prior Board approval only if the insider requests to renew the line of credit?
Also, if we have a seven year Home Equity Line of Credit (HELOC) to an insider that did not require Board approval and later obtained Board approval on another loan for the insider's related interest (due to the aggregate amount exceeding $500,000), do we now have to go to the Board for any remaining HELOC amount?
Again, any helpful input will be greatly appreciated.