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#2254284 - 05/24/21 05:40 PM Reg O (Officers & Directors of Other Banks)
CometMan Offline
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Joined: Mar 2011
Posts: 81
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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#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: 76,410
Galveston, TX
I would be asking for a citation from the examiners.
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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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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
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Joined: Mar 2011
Posts: 81
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: 76,410
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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