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In regards to Reg O, specifically executive officers, how does CD secured fit in? For example, can you loan over $100K (not for 1st lien mortgage or child's education) if the loan is CD secured? Additionally, if it is CD secured are you still required to get a financial statement?
If a bank has an employee overdraft policy where each employee is allowed (3) overdrafts annually with no fee charged, does this policy also apply to Executive Officers and Directors? Or even if there is an employee plan, paying an OD item and not charging for an overdraft for an EO or Director would be a violation of Reg O?
Are bank employees, other than executive officers, allowed to have overdraft protection on their checking accounts under Reg O?
Our Executive Officers sign on accounts for churches and other types of accounts, but they are not owners of the accounts. Is this a Reg O violation to overdraw those accounts and do they have to be charged an overdraft fee?
What is the best industry practice regarding a policy on employee overdrafts?