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#2269367 - 04/19/22 08:58 PM Reg O Reports to the Board
Live 2 Comply Offline
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Live 2 Comply
Joined: Sep 2009
Posts: 341
So we report to the Board a quarterly Reg O tracking which shows all insider loans that were approved with the date or why they did not require approval (home loan or CD secured etc). It also has interest rates of loans and deposits of the insider to show no preferential treatment was given. Does anyone else do something like this? I think this is great for the Reg O Officer to track this, but feel like it may be overkill to send this to the Board.

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Lending Compliance
#2269368 - 04/19/22 09:10 PM Re: Reg O Reports to the Board Live 2 Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Usually, all new loans are report to the board since the last meeting (has to be for executive officers) or otherwise go to the board for pre-approval. Why you would have a quarterly report on all loans, I have no idea. I am also confused by what you mean by this statement: "why they did not require approval (home loan or CD secured etc)". All insider loans require approval or pre-approval based on the outstanding amount of credit granted 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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#2269403 - 04/20/22 03:56 PM Re: Reg O Reports to the Board Live 2 Comply
TaraSue Offline
Member
Joined: Oct 2013
Posts: 60
Our quarterly Reg O reporting to the Board has three items: 1) Any reviews/approvals of loans that fall under Reg O 2) A Reg O report that lists all open loans that apply under Reg O - including origination date, end of term date, available amount (in case of HELOC), outstanding amount, interest rate, and purpose of loan. Of course, we take totals for available amount and outstanding amount and report on how those tie back to where our Reg O numbers should be regarding legal lending limit, and executive officer limits. . We do not include any information in our reports regarding how loans are secured (including not documenting interest rates for deposits). Of course, that is covered in the review/approval portion of the report. The last section of that report are an overview of the policy at a 10K foot view to give an at hand reminder of how limits apply.

While I'm not a fan of "that's the way we've always done it" the person preparing this report might have some insight into why it is done this way at your institution. Did she just inherit it and leave things the same? Did the Board request additional information within the report?

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#2280489 - 01/31/23 02:42 PM Re: Reg O Reports to the Board Live 2 Comply
mbl4250 Offline
Junior Member
Joined: Dec 2020
Posts: 30
The Board approved a reg O Loan via a loan portal with all of the board members, we have documentation on who voted and who abstained from the vote.

My Question is, do we need to report this to the Board that the Loan Originated? Board gave prior approval before the loan originated but we were not sure if this needed to go into next month's Board Packet to show that the loan originated.

Edit: One thing to add is that this loan is over the aggregate lending limit
Last edited by mbl4250; 01/31/23 02:56 PM.
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#2280490 - 01/31/23 02:58 PM Re: Reg O Reports to the Board Live 2 Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If the loan was above the preapproval threshold, that is the way it always happens. Whether or not you confirm that the loan was actually made is a business decision.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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