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How Does CD Secured Fit In with Reg O

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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?

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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