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#1718330 - 07/09/12 08:44 PM Participations & Reg O
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
Do Participated Loans count against a Director's aggregate debt? If the loan is 100% participated, does that mean the loan amount is not aggregated into his total debt?

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Lending Compliance
#1718387 - 07/10/12 07:46 AM Re: Participations & Reg O Combustible
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,367
Galveston, TX
You mean participations sold or purchased? Participations sold without recourse do not count against the insider.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1718503 - 07/10/12 03:04 PM Re: Participations & Reg O Combustible
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
Yes, sold is what I was looking for--I think my brain was fried when I posted so my apologies for not being more specific. Thanks much for your reply! I'm so glad you guys are here to answer questions from nincompoops like me!

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#1779543 - 01/24/13 06:22 PM Re: Participations & Reg O Combustible
Midwest123 Offline
100 Club
Joined: Mar 2012
Posts: 120
Just wanted to double check but let's say the loan is going to be 100% sold without recourse and the loan amount has reached the threshold where you have to get prior board approval, can we avoid this step since it is being participated and won't be included in the total once it is sold?

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#1779566 - 01/24/13 07:04 PM Re: Participations & Reg O Combustible
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,367
Galveston, TX
If the loan is on your books for one second, then Regulation O rules apply. "Going to be sold" doesn't count.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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