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.

Once they exceed the threshold ($500K) then yes, all lines of credit have to be re-approved by the board at least every 14 months.

Thank you for the prompt reply, Randy!

A Board of Director currently has a loan with our institution in his personal name, and would like to co-sign for his son’s primary residence purchase. Would this be a Reg O violation?

Only if it constituted preferential treatment. Do you typically allow such co-signers? If you normally allow if, then it would be attributed to the director's loan totals.

Thank you