Update: I reached out to the ABA for clarification as well. The following is the response I received:
"As the section indicates the provisions apply to loans made “to†an executive officer, as compared to an ‘insider’ that by definition includes their related interests (see 215.2(h)) nor by specific reference to their ‘related interests’ (e.g., see 215.9(b)(1)), the requirements under 215.5 are not applicable to loans to other than the covered person(s) identified. See also 22(g) and (h) in the Federal Reserve Act, implemented by 12 USC 375a and 375b respectively."