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Director Profile Package Submitted to FDIC

Question: 
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?
Answer: 

Dan Persfull

See the third paragraph of the interpretive letter. Although it specifically references Executive Officer I think you can apply the good faith reference to Directors as well.

Answer: 

John Burnett

After reading that letter, I think you'll agree that any loan you make to the individual should conform to the limits of Regulation O. In particular, it would probably not be viewed as "good faith" to make a loan now on terms more advantageous to the director-nominee or presenting more risk than loans or terms available to similarly-situated members of the general public.

First published on 04/13/2015

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