Latest Lending - Reg. O Topics

Reg O Preapproval by Majority of Board

06/23/2019

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?

Executive Officer-Modifying Loan Contracts

12/09/2018

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?

Reg O Apply to Overdrafts in Investment Acct?

06/10/2018

Does Reg O apply to overdrafts in an investment account?

Charge Employees Fees on Consumer Loans?

01/21/2018

Does a bank have to charge employees fees on consumer loans?

Executive officer loan limits

03/05/2017

How much can be loaned to an executive officer?

Regulation O Considerations When Bank Stock Held by a Director Is Collateral

08/31/2015

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?

Director Profile Package Submitted to FDIC

04/13/2015

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?

Demand Feature for Executive Officer on OELC?

06/16/2014

Can you have the demand feature for an executive officer on an open end line of credit?

Primary Residences Subject to Reg O Reporting?

05/12/2014

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?

Reg O Demand Clause In Note for OD?

04/28/2014

For Reg. O compliance, is a Demand Clause required to be included in the Note for overdraft loans to executive officers?