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#2132469 - 05/31/17 02:49 PM Reg O Overdrafts - how account ownership applies
MMA Offline
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Joined: Aug 2012
Posts: 21
Reg O 215.4(e)(1) states: No member bank may pay an overdraft of an executive officer or director of the bank...unless...

Does this only apply to overdrafts on accounts owned in sole or joint ownership by an EO or Director? What if the EO or Director is Guardian, Custodian, or Signer on the account?

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#2132621 - 06/01/17 12:28 PM Re: Reg O Overdrafts - how account ownership applies MMA
TINKerBell Offline
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TINKerBell
Joined: Nov 2006
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This prohibition does not apply to the payment by a member bank of an overdraft of a principal shareholder of the member bank, unless the principal shareholder is also an executive officer or director. This prohibition also does not apply to the payment by a member bank of an overdraft of a related interest of an executive officer, director, or principal shareholder of the member bank or executive officer, director, or principal shareholder of its affiliates
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#2132724 - 06/01/17 05:28 PM Re: Reg O Overdrafts - how account ownership applies MMA
MMA Offline
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Joined: Aug 2012
Posts: 21
I read that in the regulation, but that doesn't address my question about the EO or Director being in a less-than-ownership capacity on an account. I know related interests and principal shareholders are exempt from this.

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#2132727 - 06/01/17 05:42 PM Re: Reg O Overdrafts - how account ownership applies MMA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,380
Galveston, TX
Guardian, Custodian, or Signer on the account?

In this circumstance, based on the specifics of the relationship to the executive officer, the underlying account would most likely belong to a related interest.
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