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How Does CD Secured Fit In with Reg O

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Question: 
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?
Answer: 

You can lending an unlimited amount if the loan is CD secured and held at your bank.

215.5(c)(3) In any amount, if the extension of credit is secured in a manner described in Sec. 215.4(d)(3)(i)(A) through (d)(3)(i)(C) of this part;

215.4(d)(3)(i)(C) Extensions of credit secured by a perfected security interest in a segregated deposit account in the lending bank;

All other requirements under 215.5(d) will still apply.

First published on 02/26/2017

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