I work for a foreign bank that has branches in the US, with only one insured deposits branch.
Does Regulation O apply to a foreign bank as it does to a domestic branch?
Section § 215.1(b) reads:
(b) Purpose and scope--(1) This part governs any extension of credit made by
a member bank to an executive officer, director, or principal shareholder of
the member bank, of any company of which the member bank is a subsidiary, and
of any other subsidiary of that company. (2) This part also applies to any
extension of credit made by a member bank to a company controlled by such a
person, or to a political or campaign committee that benefits or is
controlled by such a person. (3) This part also implements the reporting
requirements of 12 U.S.C. 1817(k) concerning extensions of credit by a member
bank to its executive officers or principal shareholders (or to the related
interests of such persons). (4) Extensions of credit made to an executive
officer, director, or principal shareholder of a bank (or to a related
interest of such person) by a correspondent bank also are subject to
restrictions set forth in 12 U.S.C. 1972(2).
And member bank is defined as:
(j) Member bank means any banking institution that is a member of the
Federal Reserve System, including any subsidiary of a member bank. The term
does not include any foreign bank that maintains a branch in the United
States, whether or not the branch is insured (within the meaning of 12 U.S.C.
1813(s)) and regardless of the operation of 12 U.S.C. 1813(h) and 12 U.S.C.
However, section 12 U.S.C. 1828(j)(3)(B) reads:
(B) EXTENSIONS OF CREDIT TO OFFICERS, DIRECTORS, AND PRINCIPAL
SHAREHOLDERS.--Paragraph (2) shall not apply with respect to a foreign bank
solely because the foreign bank has an insured branch, but shall apply with
respect to the insured branch.
And I assume this last part applies to Reg W, right?
Will Reg O apply to the bank or not, or partially?
Do the restrictions on loans to executive officers apply to PPP loans?
How long will the Interim Final Rule (IFR) stay in place?
When is the new Federal Reserve Interim Final Rule on PPP loans effective?
On commercial loan requests we will sometimes deviate from the interest rates listed on our rate sheet (those rates offered to the general public) for reason of matching the rate being offered by a competing lender.
We will report this as an interest rate pricing exception for reason of competitive disadvantage. My question is, does this same interest rate pricing exception constitute a Reg O violation when granted to a bank director?
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?