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#2256729 - 07/15/21 02:43 PM Reg O Question
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
We have a car loan which was made to the daughter of an Officer of the Bank prior to his becoming a Bank employee. The Officer is not a co-signor, and I'm being told that she qualified for the loan on her own when she applied, and the amount is less than $25,000.

Occasionally the father will transfer money from an account he maintains at another financial institution to help her with the monthly payment. Should this loan be classified as a Reg. O loan? If so, is there any additional reporting that we need to implement?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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Lending Compliance
#2256733 - 07/15/21 03:14 PM Re: Reg O Question ACBbank
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,985
Galveston, TX
If he does not have any direct or indirect liability and does not drive the car around, then I think it could be excluded. If you want to be overly conservative, you could always count it. It would not be a problem unless he wanted to get a future loan for an "other purpose" and went over the $100,000 limitation.
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#2256736 - 07/15/21 03:41 PM Re: Reg O Question ACBbank
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
Thank you Randy. As always I'm grateful for your help.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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