Quick Reference of Primary Reg O Rules - Bankers Online

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Quick Reference of Primary Reg O Rules

by Patti Blenden

Insider Provisions

Non-preferential loan terms

Single Insider Lending Limit and Aggregate Insiders Lending Limit

Prior approval by entire board required to exceed aggregate loan limit of the lesser of $25,000 or 5% unimpaired capital plus unimpaired surplus (UCUS), not to exceed $500,000

More restrictive lending limits: Individual aggregate loan limit of the lesser of $25,000 or 2.5% of UCUS, not to exceed $100,000

Current detailed financial statement for new loans

Written demand feature in note

Non-preferential overdrafts with $1,000 limit

12 month re-approval for Line of Credit requirement

14-month re-approval of credit lines over prior approval threshold

Board reporting of loans secured by nonpublicly traded stock of institution on an annual basis

Names of insiders made available upon request from public when outstanding balances exceed prior approval threshold (C)

Quarterly Call Report Schedule RC-M of aggregate amount and number of credit extensions to insiders and their related interests

Financial Institution

Executive Officer (A)

X X2

Director

X X2

Principal Shareholder

(B)

X

X

X2

X2

X

X

X

X

X2

X2

X

X2

X2

X

X

X

X

X

X

X

X

Holding Co & Affiliates

Executive Officer

X1 X1, 2

Director

X4 X2, 4

Principal Shareholder

(B)

X

X

X1, 2

X2, 4

X

X1, 2 X1 X2 X3

X2, 4 X3

X

X

X

X

NOTE: See Regulation O for additional rules and conditions. All rules apply to both insiders and their related interests, unless stated otherwise. Remember that a single individual may serve in more than one insider capacity. Review and apply requirements representing each and every insider capacity. Banks with deposits of less than $100 million may be subject to a higher limit if they meet certain safety and soundness qualifications.

1. This rule applies to executive officers of other subsidiaries unless a special board resolution has been passed by the financial institution. Special provisions apply as to when you can exclude. You cannot ever exclude larger subsidiaries (>10% of consolidated bank holding company assets).

2. Overdraft rules do not apply to related interests of the executive officer or director. However, overdrafts of related interests do count when calculating aggregate and individual lending limits.

3. Rules related to board reporting of loans secured by the institution's privately traded stock do not apply to executive officers and directors of other subsidiaries which are not financial institutions.

4, Exclusion available to affiliate directors only if small affiliate ( ................
................

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