Loan Reporting, Guru Follow Up

In reference to the question below, would you also be required to report a loan to a mortgage company that is not affiliated with any bank? Ex Officer Reporting Loans from other Banks by Randy Carey, BOL GuruQuestion: 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