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#1450294 - 09/30/10 05:20 PM Is it Reg O if a BOD is a guarantor
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
Is a loan considered Reg O if a board member is a guarantor, but not the borrower?

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Lending Compliance
#1450311 - 09/30/10 05:37 PM Re: Is it Reg O if a BOD is a guarantor Many Hats
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, the guaranty brings it under Reg O to the extent the loan is a guaranteed. If a 50% guarantee, 50% of the loan is counted toward that director's Reg O limit.

If the loan is to a related interest, the entire loan is counted toward Reg O limit, regardless of any limit on the guaranty.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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