Reg O Question

Posted By: ACBbank

Reg O Question - 07/15/21 02:43 PM

We have a car loan which was made to the daughter of an Officer of the Bank prior to his becoming a Bank employee. The Officer is not a co-signor, and I'm being told that she qualified for the loan on her own when she applied, and the amount is less than $25,000.

Occasionally the father will transfer money from an account he maintains at another financial institution to help her with the monthly payment. Should this loan be classified as a Reg. O loan? If so, is there any additional reporting that we need to implement?
Posted By: rlcarey

Re: Reg O Question - 07/15/21 03:14 PM

If he does not have any direct or indirect liability and does not drive the car around, then I think it could be excluded. If you want to be overly conservative, you could always count it. It would not be a problem unless he wanted to get a future loan for an "other purpose" and went over the $100,000 limitation.
Posted By: ACBbank

Re: Reg O Question - 07/15/21 03:41 PM

Thank you Randy. As always I'm grateful for your help.