While working on a Reg O audit, I came across an executive officer who got a loan, but their financial statement we had on file was dated about 22 months before the date of the loan... I know the reg says we must have a "current" financial statement when making a loan to an executive officer, but I can't find anything to specify what "current" is. Any input?

Of course I don't think anyone would consider 22 months old to be "current" but just wondering what to suggest as a rule of thumb going forward? Within 12 months?

i would consider current to be the period immediately preceding the loan request, so within 30 days. however, also depending on the type of loan, amount, and if a prior loan already on the books, that may change to a longer period.

Let me ask you what your written policy states when someone applies for a loan that calls for providing a current financial statement? What is acceptable? If it is not 22 months, then you have an automatic Reg O violation for preferential treatment.