Exec. wants to borrow more $ for home improvements to residence. We are considering a $100,000. HELOC loan. This would be a second one behind the first HELOC for $90,000. The first is counted toward the $100,000. Reg O limit and has no restrictions. Providing this second is not typical for us to do as a product. Is what we wish to do OK for Reg o purposes? Can someone cite the section of the Reg. that addresses this. Thanks!

You are limited to a total of $100,000 to an executive officer, with the exception of a home purchase loan or a loan to pay for the education of his children. $190,000 exceeds that limit.

Reg O says,

"(c) A member bank is authorized to extend credit to any executive officer of the bank:
(1) In any amount to finance the education of the executive officer's children;
(2) In any amount to finance or refinance the purchase, construction, maintenance, or improvement of a residence of the executive officer, provided:

(i) The extension of credit is secured by a first lien on the residence and the residence is owned (or expected to be owned after the extension of credit) by the executive officer;"

You could loan additional money to the exec for improvement, but since it has to be on a first lien, you'd need to combine the existing HELOC and the new money into one loan secured by a first lien on his/her residence.