Here's some additional information.
https://www.federalreserve.gov/supe...ons/reg-o-frequently-asked-questions.htmQ2: May a member bank offer a discount on loan origination fees to an insider if the discount is not available to members of the public?
A2: No, with one exception, explained below. Regulation O prohibits a member bank from extending credit to an insider that is not made on substantially the same terms as, or is made without following credit underwriting procedures that are at least as stringent as, comparable transactions with persons that are non-insiders and not employees of the bank. 12 CFR 215.4(a)(1). This provision does not, however, prohibit a member bank from extending credit to an insider as part of a benefit or compensation program that (i) is widely available to employees of the member bank and (ii) does not give preference to any insider of the member bank over other employees of the member bank. 12 CFR 215.4(a)(2).
Source: FRRS 3-1089.11 (citing Letter from J. Virgil Mattingly, General Counsel of the Board, to Gary S. Dubrow, Esq. (June 3, 1993), available here).
Posted: 3/31/2021 (revised 12/30/2021)