01/01/2006
12/01/2005
The FFIEC has sent out a reminder to banks that the time for annual reports of indebtedness is coming up. The reminder includes a sample form.
12/01/2005
12/01/2005
10/17/2005
I believe that Reg O says that a bank can pay overdrafts on an account on which a director is a signer, but I am wondering if the bank can waive the overdraft fees?
10/17/2005
Is the Reg O Demand Feature provision required on loans made only to executive officers, or does it also include directors?
10/03/2005
Our bank offers a checking account (The Club Account) to customers for a fee of $7 per month with various benefits including unlimited check writing, free checks, no minimum monthly balance, etc. Employees receive the account for no monthly charge. Are executive officers also allowed to receive the account for no charge? It is my understanding that executive officers cannot receive more favorable terms than customers.
08/29/2005
I have a question in regards to Reg O Insider loans. Our financial institution originates loans and sells them to the secondary market. The secondary market lender approves the loans, our financial institution funds the loans and carries them on our book for about a week. If we process a secondary market loan for a Reg O officer and sell it to the secondary market is this considered a Reg O loan? Does the following part of the regulation apply? Any extension of credit to an executive officers shall be: Made subject to the condition in writing that the extension of credit will, at the option of the member bank, become due and payable at any time that the officer is indebted to any other bank or banks in an aggregate amount greater than the amount specified for a category of credit in paragraph (c) of this section.
07/18/2005
Do Regulation O provisions apply to mortgage loans extended to executive officers which are sold to investors by the bank? These loans have an investor commitment up front and are held by the bank for 30-60 days only before sale. Also, mortgage refinancing provisions appear to exclude equity extraction mortgage loans unless the proceeds are used to further improvements in the primary residence. Is this an accurate interpretation?
12/01/2004
The annual reports on indebtedness to be filed by executive officers and principal shareholders must be filed in January for the year 2004. The forms are now available.