The bank is wanting to implement an "Employee Assistance Program". The purpose is to assist employees when they fall on a personal hardship. The employees can make contributions via payroll deduction, one time contributions or not at all. The employee doesn't have to participate in the program to receive any benefit of it. I'm looking for any information or feedback you might have regarding an employee assistance program. I can see that there could be many challenges with implementation and maintaining such a program. Specifically, what regulatory or compliance pitfalls do you see?
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?
What restrictions does Regulation O place on overdrafts?
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?