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Ex Officer Reporting Loans from other Banks

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Question: 
Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "Banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states 215.9 Reports by Executive Officers "Executive officers must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."
Answer: 

The term "bank" alone is not defined within the regulation. I would interpret it to be defined very broadly and would include any type of bank, whether a member bank or not.

First published on BankersOnline.com 1/30/06

First published on 01/30/2006

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