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#2304642 - 01/03/25 07:18 PM Reg O "Related Interests" - Include Director?
Tarhe Online
Diamond Poster
Joined: Nov 2006
Posts: 1,474
California
One of directors passed away just after Christmas. Our report of Related Interests for Reg O is as of 12/31. Do we remove him from the report?

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Lending Compliance
#2304657 - 01/03/25 10:35 PM Re: Reg O "Related Interests" - Include Director? Tarhe
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 85,230
Galveston, TX
What report?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2304662 - 01/04/25 12:58 AM Re: Reg O "Related Interests" - Include Director? Tarhe
Tarhe Online
Diamond Poster
Joined: Nov 2006
Posts: 1,474
California
We create an annual report of all of our insiders and their related interests. Maybe it's just an internal report we do for identifying deposit accounts and loans subject to the Reg O lending rules, so please disregard.

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#2304663 - 01/04/25 02:18 PM Re: Reg O "Related Interests" - Include Director? Tarhe
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,793
Florida
Tarhe, even if it's an internal report, I guess it would depend on the purpose of the report.
If it's to reflect the indebtedness of current (active) directors as of a point in time, no.
If it's to reflect the amount of lending to directors during the year, yes.
Even if it were the former, a footnote might be appropriate.
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#2304665 - 01/05/25 03:51 PM Re: Reg O "Related Interests" - Include Director? Tarhe
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 85,230
Galveston, TX
Are you talking about a survey to meet this requirement? If he has passed away, who is going to complete the survey and why?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2304683 - 01/06/25 05:02 PM Re: Reg O "Related Interests" - Include Director? Tarhe
Tarhe Online
Diamond Poster
Joined: Nov 2006
Posts: 1,474
California
Thank you for the comments. I agree with both - the survey was not completed. Thank you for your thoughts!

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