Answer:
Answer by Richard Insley: If the employee also happens to be an executive officer, you have Reg. O issues. Otherwise, I don't know of any restrictions.
Answer:
Answer by Andy Zavoina: 215.4(a)(2) of Reg. O does allow that a widely available employee benefit plan may provide for loan discounts. "Widely available" means that it isn't going to be used only by senior management on $500,000 homes. Other restrictions and sound underwriting guidelines still apply. You would be wise to have this benefit approved by the board and well defined, what discounts apply, when and what is needed to qualify for it. Again, it would reflect negatively if it was only used by Reg. O insiders.
First published on BankersOnline.com 11/1/04
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