Reg O

Posted By: Manny

Reg O - 03/22/07 11:18 AM

Reg O explains what a tangible economic benefit to the insider is.

I can see where an extension of credit to an insider’s spouse would be an economic benefit to the insider. Perhaps an extension of credit to an insider’s minor child could be an economic benefit to the insider (the insider or spouse may have co-signed for the minor child).

Does an extension of credit to an insider’s adult children living at home really provide an economic benefit to the insider?

Does Reg O extend to every member of that household?
Posted By: Sinatra Fan

Re: Reg O - 03/22/07 01:14 PM

Definition of "immediate family" from Regulation O, Section 215.2(g):

Immediate family means the spouse of an individual, the individual's minor children, and any of the individual's children (including adults) residing in the individual's home.

So, the answer to your question is "Yes."
Posted By: rlcarey

Re: Reg O - 03/23/07 03:05 PM

While immediate family is defined in Reg O - IMHO - that is not a determining factor.

If the insider co-signed the loan, it is covered no matter who is the primary borrower.

Read the staff opinion in this post: http://www.bankersonline.com/forum/ubbth...true#Post701722

I believe these conditions most likely apply for the conditions you describe whether or not you are specifically talking about a spouse or an adult child at home.
Posted By: bcompliance

Re: Reg O - 09/01/21 07:03 PM

Executive officer's adult child is living at their home and the child gets a mortgage in their name only through the bank. I am assuming this does not fall into an "extension of credit" where we'd need a demand clause singed by the EO because the executive officer is not benefitting from the transaction and are not actually on the loan? I agree with what Randy is saying above but would like to get a second opinion
Posted By: rlcarey

Re: Reg O - 09/01/21 07:38 PM

Why would the child that is living at home get a mortgage loan? Did they qualify on their own?
Posted By: bcompliance

Re: Reg O - 09/01/21 07:40 PM

They bought a house to move out of EO parent's house, qualified on their own and applied individually
Posted By: rlcarey

Re: Reg O - 09/01/21 08:04 PM

Not a Reg O loan then.