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#532678 - 04/17/06 07:27 PM REg. O - Executive Officer
Jerseygirl Offline
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
I have been asked to submit a financial statement and copy of my tax returns as part of compliance w/ Reg. O. I have never don't this at other places I've worked and can't find the part of a reg that says I have to. I don't mind providing when I'm appling for a loan and I don't mind the annual notice of indebtedness but is this also required.

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Lending Compliance
#532679 - 04/17/06 07:42 PM Re: REg. O - Executive Officer
complyaudit2 Offline
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complyaudit2
Joined: Apr 2002
Posts: 119
If you are an Executive Officer of the institution, stricter requirements apply. An Executive Officer is a person who has policy making ability within the institution even if the job title does not state VP or higher.

See 215.5(d)(3) for requirements. EO must first submit a current financial statement; extension of credit must be promotely reported to the board; AND the extension of credit must include a written demand clause.

If you are not an EO, but your insitutions loan policy states all bank staff employee loans require current financials, then it is a bank requirement. Also, some state laws required all salaried officers to provide this documentation even if the officer is not an EO.

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#532680 - 04/17/06 08:24 PM Re: REg. O - Executive Officer
Jerseygirl Offline
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
As an EO it is not required by Reg. O but it could be bank policy (which it is not here).
So unless it's a line of credit that is due for renewal, annual fins. are not required by the reg.

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#532681 - 04/17/06 09:06 PM Re: REg. O - Executive Officer
PJ Offline
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Joined: Sep 2005
Posts: 115
Regarding Reg O - if the purpose isn't loan related, maybe they want to use financials to help determine related interests?????
I have seen banks that require all officers to submit annual financials to either comply with state law requirements (state chartered institutions) or to monitor for who might be financially strapped (I guess they thought they would be a bigger risk for fraud?)

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#532682 - 04/18/06 01:48 PM Re: REg. O - Executive Officer
pa...leez Offline
New Poster
Joined: Mar 2006
Posts: 12
FL, USA
What if you refuse to provide unless you get a clearer explanation. Yes the bank knows your wages, but they need to know your entire financial info if your not applying for a loan? I have had that to come and haunt me and vowed never to bank where I work. I would have real issue with that. (If I am a millionaire and choose to work for entertainment, it should not be their business. On the other hand if I am financially strapped, they should check my checking activity for possible kiting, high volumes, etc.)

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#532683 - 04/25/06 07:48 PM Re: REg. O - Executive Officer
SonnyGirl Offline
Gold Star
Joined: Feb 2004
Posts: 391
Regulation O does not absolutely require financial statements of executive officers to be submitted (unless a loan has been requested), however, current financial statements are always required in FDIC safety and soundness exams and in our state exams (Tennessee), therefore, we request financial statements when updating related interests files on executive officers (directors also as examiners require FS's on directors).

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