I have a question on Reg O, specifically the preapproval by the majority of the entire board of directors requirement under 215.4.
1. If the board of Directors authorizes a sub-committee to act on behalf of
the entire board, would pre-approval by that sub-committee satisfy the regulatory requirement regarding approval by a majority of the entire Board of Directors?
2. What if the majority of that sub-committee was composed of senior
management, the remaining minority members were board members and the total number of board members on the committee did not constitute a majority of the entire board?
In the first quarter 2018 I was added as an executive officer for our bank. I currently have a home loan, a HELOC and a vehicle installment loan with our bank which were all originated prior to my becoming an executive officer. The aggregate amount owed is under $100,000. The home loan and HELOC will balloon in the coming year. Am I correct that the Reg O demand clause is not required to be added to my loan documents until the loans are renewed, extended or modified or should my loan contracts have been modified when I became an executive officer?
Does Reg O apply to overdrafts in an investment account?
Does a bank have to charge employees fees on consumer loans?
How much can be loaned to an executive officer?
One of our bank directors has an adult relative who is starting a new business venture. This relative wants to get financing from the bank, and part of the collateral securing the loan would be bank stock pledged by the director. The director has no beneficial ownership in this new business venture and simply wants to help the relative get the business up and running. What, if any, Regulation O implications are involved with this scenario?
If the bank has submitted a director profile package to the FDIC and he/she has not been approved as of yet, would a loan to this person be considered a Reg O loan?
Can you have the demand feature for an executive officer on an open end line of credit?
Reg O - Directors (not Executive officers). Are primary residences subject to Reg O reporting for directors? Are there specifics to when they are or not be be reported such as on the mortgage system, loan side, 2nd lien or purpose like Executive officers?
For Reg. O compliance, is a Demand Clause required to be included in the Note for overdraft loans to executive officers?