We have Executive Officers that have borrowings at other institutions that exceed our internal $100,000 limit for Executive Officers. Some of these Executive Officers have borrowings at our bank in addition to the other borrowings, however some do not. Can you please let me know when the borrowings at the other institution need to be initially reported to our board? After the initial reporting, how often or when do these borrowings at another institution need to be reported to the Board?

Reg O requires that such borrowings at other banks be reported to the EO's bank within 10 days of incurring aggregate debt at all other banks that exceeds what the EO can legally obtain at his/her own bank. In this context, "legally" refers to the limits in Reg. O, not any policy limits adopted by the bank.

There is no periodic updating required, although the EO does have to keep filing detailed personal financial statements with the board before doing any additional borrowing from his/her own bank. Presumably the FSs will include the other bank borrowings.

Is the other "institution" a bank or another type of lender? It makes a difference under Reg O. Is the other "institution" a correspondent bank of your bank? That also makes a difference in reporting.

Steve's correct. We kick around the terms "financial institution" and "bank" a lot, and in some cases, the loans are obtained from a lender that does not trigger the Reg. O reporting requirement.

If the lending FI is a correspondent of your bank, there will be year-end reporting on form FFIEC 004 as long as the debt (and the corespondent relationship) continue.