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#704808 - 03/22/07 11:18 AM Reg O
Manny Offline
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Joined: May 2006
Posts: 54
Midwest
Reg O explains what a tangible economic benefit to the insider is.

I can see where an extension of credit to an insiders spouse would be an economic benefit to the insider. Perhaps an extension of credit to an insiders minor child could be an economic benefit to the insider (the insider or spouse may have co-signed for the minor child).

Does an extension of credit to an insiders adult children living at home really provide an economic benefit to the insider?

Does Reg O extend to every member of that household?

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Lending Compliance
#704854 - 03/22/07 01:14 PM Re: Reg O Manny
Sinatra Fan Offline
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New Jersey
Definition of "immediate family" from Regulation O, Section 215.2(g):

Immediate family means the spouse of an individual, the individual's minor children, and any of the individual's children (including adults) residing in the individual's home.

So, the answer to your question is "Yes."
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#705631 - 03/23/07 03:05 PM Re: Reg O Sinatra Fan
rlcarey Online
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rlcarey
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Galveston, TX
While immediate family is defined in Reg O - IMHO - that is not a determining factor.

If the insider co-signed the loan, it is covered no matter who is the primary borrower.

Read the staff opinion in this post: http://www.bankersonline.com/forum/ubbth...true#Post701722

I believe these conditions most likely apply for the conditions you describe whether or not you are specifically talking about a spouse or an adult child at home.
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#2259111 - 09/01/21 07:03 PM Re: Reg O Manny
bcompliance Offline
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Executive officer's adult child is living at their home and the child gets a mortgage in their name only through the bank. I am assuming this does not fall into an "extension of credit" where we'd need a demand clause singed by the EO because the executive officer is not benefitting from the transaction and are not actually on the loan? I agree with what Randy is saying above but would like to get a second opinion
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#2259113 - 09/01/21 07:38 PM Re: Reg O Manny
rlcarey Online
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Galveston, TX
Why would the child that is living at home get a mortgage loan? Did they qualify on their own?
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#2259114 - 09/01/21 07:40 PM Re: Reg O Manny
bcompliance Offline
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They bought a house to move out of EO parent's house, qualified on their own and applied individually
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#2259116 - 09/01/21 08:04 PM Re: Reg O Manny
rlcarey Online
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Galveston, TX
Not a Reg O loan then.
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