Are there any exceptions to 215.5(d)(3) - any extension of credit to an Executive Officer must be preceded by the submission of a detailed current financial statement? I can not find any exceptions even for a home equity line of credit secured by a 2nd lien on principal dwelling. I have someone saying there is an exception but I can not find it.
Posted By: rlcarey
Re: Reg O loans - 04/03/06 07:52 PM
You are correct - there are no exceptions.
Ok, now an added question - is "current" defined? What is considered a current financial statement?
What does your loan policy consider a current F/S for your loan customers? We consider a F/S current if it is within 12 months from the date of the transaction. You can't give your EO preferential treatment. IOWs if you require your loan customers to have a F/S dated within 6 mos of the transaction, then your EO's F/S should be dated within 6 months.