Situation: Bank Director's spouse owns 100% of a corporation that has applied for a commercial real estate loan. The repayment is to come from lease payments from a business that is owned 20% by Director's spouse and 80% by her children (2nd marriage so children are not children of director). There are no preferential terms and loan complies with all lending policy. I am saying the director has no tangible economic benefit and therefore not a Reg O loan - any agree or disagree.

Agree

Bank Director's spouse owns 100% of a corporation.

Whether or not she owns the company in her name, is this totally separate property with no proceeds of the corporate income benefiting the director?

And the director is truly not pulling the strings, regardless of whose name islisted as owner?

thanks for all your feedback.