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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