reg O

Does the limitations on reg O restrict loans to exec officers to primary residence only? I am not famialr with it, however, in reading it, it simply states residence. I have an exc who wants to refi his house and blanket the property with a second home. The loan would be a first lien on both. Any information would be helpful.

I am by no means an expert on Reg O but it's my understanding that you can exceed the $100,000 limit for loans for purchase, construction, maintenance or improvement of a residence of Officer. I have seen explanations that say this can be for a second home or vacation home.

What is the purpose of the second home? If it's a guest house I think you may have a good argument. One could argue that a guest house on the same property is still the residence. If it is an investment rental I would be concerned about the "residence" requirement.

"blanket the property with a second home"

Why? The Reg O rules apply to one loan secured by one residence. I think this is going to throw this loan into never-never land as there is no regulatory guidance for this situation and could raise questions in a regulator's mind and you are going to be in a position to defend it with nothing to back you up.

That is what I thought....I looked all over and advised to stay away from it. It seems that the other property is a vacation home. I read the refi requirements which would has restriction on it. I beleive anything over that amount woule fall into other purposes with the 100k limit. Its a real mess.