Secretary's of the Board of Director's are subject to Reg O lending guidelines, correct? The statute says executive officers, directors, and their related interests. Although a Secretary is not a Director, they are closely related to the Board and they are privy to all that the Board knows...Does that subject them to Reg O?

There are a number of positions that are automatically considered executive officers unless specifically excluded. Your Board should have passed a resolution naming who specifically is an executive officer or who is excluded. You may want to review the past Board minutes to figure this out. The section of the pertinent portion of Reg O is included below and is taken from 215.2.

The chairman of the board, the president, every vice president, the cashier, the secretary, and the treasurer of a company or bank are considered executive officers, unless the officer is excluded, by resolution of the board of directors or by the bylaws of the bank or company, from participation (other than in the capacity of a director) in major policymaking functions of the bank or company, and the officer does not actually participate therein.