Skip to content
Thread Options
#27975 - 08/15/02 12:45 PM Reg. O-Detailed Current Financial Statement

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?

Return to Top
Lending Compliance
#27976 - 08/15/02 03:36 PM Re: Reg. O-Detailed Current Financial Statement
Andy_Z Offline
10K Club
Joined: Oct 2000
Posts: 27,556
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.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#27977 - 08/19/02 02:57 PM Re: Reg. O-Detailed Current Financial Statement
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
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.
My opinions are not legal advice and are worth what you paid for them.

Return to Top

Moderator:  Andy_Z