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#2254284 - 05/24/21 05:40 PM Reg O (Officers & Directors of Other Banks)
CometMan Offline
Member
Joined: Mar 2011
Posts: 83
We have received an exam letter that asks us to disclose all loans to Officers and Directors of OTHER financial institutions. Am I missing something regarding Reg O? Do we need to be handling loans differently for Officers and Directors of Banks that are NOT affiliated with our institution?

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Lending Compliance
#2254297 - 05/24/21 07:56 PM Re: Reg O (Officers & Directors of Other Banks) CometMan
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I would be asking for a citation from the examiners.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2254431 - 05/26/21 02:09 PM Re: Reg O (Officers & Directors of Other Banks) CometMan
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,668
Are you a Correspondent Bank, or have accounts at Correspondent Banks?
Last edited by Compliance NABW; 05/26/21 02:11 PM.
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#2254614 - 05/28/21 03:10 PM Re: Reg O (Officers & Directors of Other Banks) Compliance NABW
CometMan Offline
Member
Joined: Mar 2011
Posts: 83
We do have accounts with a correspondent bank in order to initiate and receive wire transfers.

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#2254631 - 05/28/21 04:01 PM Re: Reg O (Officers & Directors of Other Banks) CometMan
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Then they are probably driving at 12 USC 1972(2):

https://www.law.cornell.edu/uscode/text/12/1972
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2259025 - 08/31/21 04:52 PM Re: Reg O (Officers & Directors of Other Banks) CometMan
Auditor1992 Offline
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Joined: May 2016
Posts: 3
Came across this thread as similar question came up at our bank. Where can I find the definition for correspondent bank as relates to 12 USC 1972(2)? Does having participations purchased from a bank qualify as correspondent bank where stated reg would apply for terms to a director, PS or EO?

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