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#723 - 02/20/01 03:06 PM Loans to Insiders
De Vonne Offline
Member
Joined: Jan 2001
Posts: 84
A new director is added to the board. The individual has a dealer floor plan with the bank of over $1 million. How should this be viewed in light of Regulation O requirements?

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General Discussion
#724 - 02/23/01 03:48 AM Re: Loans to Insiders
A D Virr Offline
Gold Star
Joined: Oct 2000
Posts: 398
Derry, NH
De Vonne, I have seen this question come up before. If the director's outstanding balances including the floor plan exceed Reg O limits - the floor plan of the entire amount would be grandfathered. Future extensions of credit would be subject to the limits of the individuals aggregate when the dealer was elected to the board. I know of no requirements that would force a newly director to divest themselves of their loans. If I'm not correct on this issue, someone will pick up on it.


This is my opinion only - no guarantees

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Allan D. Virr, CRCM

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Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC

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#725 - 02/23/01 04:24 PM Re: Loans to Insiders
redsfan Offline
Power Poster
redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
If and when you rernew or refinance the outstanding loan, it will then be subject to the Reg O requirements regarding limits, approval, and terms.
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The opinions expressed here are personal and do not represent opinions of my employer.

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