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#2257257 - 07/27/21 05:29 PM Reg O Fun Never Stops
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Bank A is a wholly owner subsidiary of Bank B. Bank A issues credit cards. An Executive Officer of Bank B opens a $50,000 credit card at Bank A. Does Bank A need the Due on Demand statement? The individual that got the credit card is not an Executive Officer of Bank A.

Conversely, an Executive Officer at Bank A gets a car loan for $35,000 at Bank B. Does Bank B need the Due on Demand clause? The individual who got the car loan is not an Executive Officer at Bank B.

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#2257261 - 07/27/21 05:44 PM Re: Reg O Fun Never Stops Working From Home
rlcarey Offline
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rlcarey
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Galveston, TX
You have a bank that owns another bank as a subsidiary and not through a bank holding company? I was not aware that was possible.
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#2257264 - 07/27/21 06:01 PM Re: Reg O Fun Never Stops Working From Home
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Yes, that is correct.

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#2257268 - 07/27/21 06:29 PM Re: Reg O Fun Never Stops Working From Home
rlcarey Offline
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rlcarey
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Galveston, TX
OK - if you say so.

In your first scenario, if Bank B controls Bank A, then in your first example it is a Reg O loan.

In the second scenario, unless the executive officers of Bank A are excluded from being considered executive officers of Bank B by a board resolution by Bank B, it would be a Reg O loan.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2257270 - 07/27/21 06:51 PM Re: Reg O Fun Never Stops Working From Home
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Thanks for the info That is just what I was thinking. Appreciate your input.

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