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#27975 - 08/15/02 12:45 PM Reg. O-Detailed Current Financial Statement
Anonymous
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We are currently preparing to submit a loan to our Board of Directors (who gives final approval on insider loans) for one of our executive officers. However, our executive officer did not complete the personal balance sheet that is used for most customers (but not required for bank employees) on our standard credit application. Now our banker is hesitant to ask the E.O. for this information, mainly since our underwriting department gave its OK to the loan through standard procedures (i.e. credit bureau, etc). My question is: is there a standard, universal definition of "detailed current financial statement", or, using the credit bureau and information available in our 10-K report, would this be enough information to demonstrate to an examiner that we have obtained a detailed current financial statement preceding final approval?

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Lending Compliance
#27976 - 08/15/02 03:36 PM Re: Reg. O-Detailed Current Financial Statement
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
I know of no formal definition, but would certainly consider a detailed financial to include all assets, liabilities and income. I would expect no less from an employee than a regular customer.

Employee financials may be held for safe keeping in the CEOs office or elsewhere for privacy and confidentiality. But they must be complete.
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AndyZ CRCM
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#27977 - 08/19/02 02:57 PM Re: Reg. O-Detailed Current Financial Statement
SJB Offline
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SJB
Joined: Jun 2002
Posts: 1,210
California
Unless you have a written policy that waives financials from employees you are inviting criticism. You can have an employee loan program that is more favorable than provided the general public but I would want it in writing.

We just use the regular loan application for everyone and the examiners have not questioned it.
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