We have a situation where we acquired a bank. A director of the acquired bank has an outstanding personal unsecured line of credit in the amount of $600,000. This particular director was then named Executive Officer of the acquiring bank. Since the $600,000 LOC was originally made as a Reg O Loan to a director, would this fall under the extension of credit exemption? The LOC is to be renewed June 2015. Thank you.

You are not going to be able to renew it.

See the next to last paragraph in the linked interpretive letter:

http://www.occ.gov/static/interpretations-and-precedents/apr08/int1096.pdf

Thank you both for your responses. What would happen if th EO drew the remainder of the LOC after the promotion? Just for curiosity's sake.

First you need to read Footnote 4 in the above link.

When the line came due they would have to pay it off or at least pay it down to $100,000. Also no payment extensions, modifications, etc. can be made to the line. When it comes due and it cannot be paid at its maturiy then you will have to report it as a past due loan.

Yes, I didn't miss the tidbit footnote! That's what caught my curiosity. Thanks again for your expertise!