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Reg O - Insider’s Shares

Question: 
Reg O Section 215.10 reads: Each executive officer or director of a member bank the shares of which are not publicly traded shall report annually to the board of directors of the member bank the outstanding amount of any credit that was extended to the executive officer or director and that is secured by shares of the member bank. Question: Must the insider's name be on the report, or is it sufficient to report "one insider has X amount secured by shares of the member bank"?
Answer: 

Answer by Randy Carey: "Each executive officer or director of a member bank the shares of which are not publicly traded shall report annually to the board of directors of the member bank the outstanding amount of any credit that was extended to the executive officer or director and that is secured by shares of the member bank. "

I would read that the "Each executive officer or director of a member bank" means that each of them need to report. Reporting anonymously is not an option.

Answer: 

Answer by Jim Bedsole: Keep in mind that this report is not just about credit extended by your bank, but by any bank that is secured by shares of your bank. A couple of triggers here too. First, this requirement will not apply at all if your bank stock is publicly traded. If your stock is not publicly traded then each executive officer or director that has any loan anywhere that is secured with the bank stock has to report their balances to your board annually. This should be something you include on your annual Reg O questionnaire that each insider completes.

First published on BankersOnline.com 6/08/09

First published on 06/08/2009

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