Answer:
by Dan Persfull:
215.4 is very specific the credit has to be approved by a majority of the entire board of directors of the bank. There is no allowance in 215.4 for that approval process to be delegated to a committee.
Answer:
by Randy Carey:
That is correct. The presentation, review, discussion and approval of the loan must be sufficiently documented in the Board of Director's minutes of the board meeting. This allows for documentation of any dissenting votes by various board members. Bank failures many times are specifically related to insider abuse and board members can incur personal liability for the mismanagement of the bank. You don't just get a majority of the board in a room to vote yes on insider loans. There is a reason that the specific words "entire board of directors" is used in the regulation.
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