No. Overdrafts don't apply to related interests. From 215.4:
"3 This prohibition does not apply to the payment by a member bank of an overdraft of a principal shareholder of the member bank, unless the principal shareholder is also an executive officer or director. This prohibition also does not apply to the payment by a member bank of an overdraft of a related interest of an executive officer, director, or principal shareholder of the member bank or executive officer, director, or principal shareholder of its affiliates."
Now to clarify, you said they don't have "ownership interest". Just keep in mind that a non-profit could be subject to Reg O for loan totals if they have "control" of the company, as defined in 215.2. In other words, just because they don't have "ownership" doesn't mean they don't have "control"... but you probably already know that, I just figured I would clarify.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com