Reg O - Holding Co Officer an Insider

First, you must determine if the person in question is an excutive officer of the holding company (see definitions below). If the answer is that the person is an excutive officer, then that person is an insider for Reg. O purposes.

Definitions: (e)(1) Executive officer of a company or bank means a person who participates or has authority to participate (other than in the capacity of a director) in major policymaking functions of the company or bank, whether or not: the officer has an official title

(h) Insider means an executive officer, director, or principal shareholder, and includes any related interest of such a person.

First published on BankersOnline.com 7/13/09