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Offering Reg O Insider A Higher Rate on Deposit?

Offering Reg O Insider A Higher Rate on Deposit?

by Randy Carey:

Reg. O only addresses loans. Whether or not this would be considered insider abuse or self-dealing will be a fact based determination.


by Dan Persfull:

12 USC 376 (section 22(e) of the Federal Reserve Act)

Interest on deposits of directors, officers, and employees

(e) No member bank shall pay to any director, officer, attorney, or employee a greater rate of interest on the deposits of such director, officer, attorney, or employee than that paid to other depositors on similar deposits with such member bank.

[12 USC 376. As added by act of June 21, 1917 (40 Stat. 240); and amended by act of Sept. 26, 1918 (40 Stat. 971), which completely revised this section.]


by John Burnett:

That covers national banks and state member banks. There is, though, no comparable federal prohibition for state non-member banks. For them, it would have to be a state law restriction.

First published on 01/07/2018

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