I understand that under Regulation O the Board can adopt a resolution naming Executive Officers. If a resolution is adopted naming Senior Management as Executive Officers and they are responsible for reviewing all policies before they are submitted to the Board for approval, but an individual who is not named as an Executive Officer is responsible for maintaining the policy and submitting it annually to the Board for approval (after Senior Management has reviewed and approved it), would the person reviewing and submitting the policy to the Board be considered an Executive Officers under Reg O as participating in a major policy making function? Thank you.

NO. That person is not performing a major policy making function.

(Yes, I know you're doing all the work. BTDT.)

Thank you.

What does BTDT stand for?

been there, done that.