Question:
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 ยง 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.
1828(j)(3)(B).
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?