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#526042 - 04/03/06 07:50 PM Reg O loans
Love those Regs Offline
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Joined: Apr 2002
Posts: 292
Southern State
Are there any exceptions to 215.5(d)(3) - any extension of credit to an Executive Officer must be preceded by the submission of a detailed current financial statement? I can not find any exceptions even for a home equity line of credit secured by a 2nd lien on principal dwelling. I have someone saying there is an exception but I can not find it.
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Lending Compliance
#526043 - 04/03/06 07:52 PM Re: Reg O loans
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,352
Galveston, TX
You are correct - there are no exceptions.
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#526044 - 04/04/06 01:07 PM Re: Reg O loans
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 292
Southern State
Ok, now an added question - is "current" defined? What is considered a current financial statement?
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#526045 - 04/04/06 01:54 PM Re: Reg O loans
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,769
Bloomington, IN
What does your loan policy consider a current F/S for your loan customers? We consider a F/S current if it is within 12 months from the date of the transaction. You can't give your EO preferential treatment. IOWs if you require your loan customers to have a F/S dated within 6 mos of the transaction, then your EO's F/S should be dated within 6 months.
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