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Approving Lines of Credit to Officers Under Reg O

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Are advances on lines of credit (such as a Home Equity Line) to officers who later, during the life of the line, become Executive Officers required to be approved under Regulation O? Is each advance an "extension of credit" since a line of credit does not constitute a "binding Commitment?"

"...since a line of credit does not constitute a "binding Commitment?" I'm not sure on what that statement might be based. The existing loan is the existing loan and it can remain without any approval since it was established prior to being named an EO. If the HELOC is modified or renewed, then all Regulation O requirements will apply to it. It will have to be counted however when determining if any other loans can be made to this EO in the future.

First published on 8/27/12

First published on 08/27/2012

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