Regulation O - Holding Company Ownership

Posted By: Compliance in AR

Regulation O - Holding Company Ownership - 10/31/19 03:16 PM

I'm new to Reg O and have a question. Scenario is that the bank is owned by a holding company. If that holding company is publicly traded, and an entity owns more than 10% of the holding company's stock, does that make the entity a principal shareholder of the holding company and thus an insider of the holding company? Do we now have to monitor that entity for Reg O compliance? If so, would it be the entity itself we monitor or would it be the persons controlling such company? Thank you.
Posted By: rlcarey

Re: Regulation O - Holding Company Ownership - 10/31/19 04:07 PM

A principal shareholder of a member bank does not include a company of which a member bank is a subsidiary.

The entity does not hold 10% of the bank, they own 10% of the holding company that holds 100% of the bank stock - so no.