We have a major stockholder that is a guarantor on 2 loans to an affiliated business that are also 100% participated to another institution. The guarantys are for the full amount of each loan. I believe I include that total loan amount in my calculations for Reg.O even though the loans are participated. And in Sec.215.4 of Reg. O, can I exceed the $500,000 in (b)(2) provided the extension was approved by a majority of the board, or do I follow Section 215.4 (e) on the aggregate lending limit? These two sections seem a little contradictory to me.

"guarantor on 2 loans to an affiliated business that are also 100% participated to another institution."

Since these loan are 100% participated out, as long as there is no recourse, they are not Reg. O loans.