TOPIC: Insider

Corrected 2/22/21: Reg O calculator and worksheet to use for monitoring against Unimpaired Capital and Surplus hurdles

VP at a bank ($1.1BUSA)
There was a formula error in Column U for the public disclosure determination - thanks to the CBANC'rs who brought to my attention as well as some hidden columns left in.    

When the bank's unimpaired capital and surplus is calculated, and your monitoring has captured all insider loans, this worksheet will aid in looking at each bucket and its unique considerations to determine if the bank is in overall compliance with each of these areas.   
 
 A calculator to determine the unimpaired capital and unimpaired surplus is also on CBANC, and was uploaded to reflect call reporting changes.  Please click a "Thanks" if you like my own work that I have shared here.  Thanks

    Loans to Insiders Employee Benefit Program for Reduced Loan Rates

    Chief Compliance Officer at a bank ($372MUSA)
    Would anyone be willing to share the portion of their Employee benefit or compensation program document that discusses employee loan programs (reduced rates, waived fees, etc.).

    Reg. O states that insiders can receive preferential loan terms (when compared to general public) so long as they are part of an Employee Benefits or Compensation program that is widely available to all employees.  Our examiners and internal auditors have all stated we need something in our benefits/compensation program if we want to offer loan benefits to employees and insiders, but they wont give any guidance on what or how specific this information needs to be.  Can we just put, "all employees including insiders and non-insiders are eligible for discounted rates and reduced fees on consumer loan products?  Or do we have to have something more specific like, "All employees including insiders and non-insiders are eligible for a 1% rate reduction on consumer installment non-real estate secured loans, a 0.5% reduction on consumer real estate secured mortgages, etc..."?

      Reg O Questions - Related Interests, Reporting, Etc.

      AVP at a bank ($3.7BUSA)

      Not getting responses in another group I asked, so hoping this might reach more people! Thanks so much.

      1. Do you report related interest loans on your Call Report, and if so, do you only report the amount of % owned by the insider or do you report the full loan balance?
        1a. Which figure should be used for in-house Reg O reports?

      2. Do you track/report loans that are excluded, such as overdraft lines? Interested in the pros/cons of doing this.

      3. Are loans to related interests of an Executive Officer excluded from the $100,000 limit, and only subject to the 215.4 limitations, as long as the Executive Officer does not personally guarantee the loan?

      4. If an insider’s loan is grandfathered in due to timing of insider election, do you still obtain a demand clause or do you just notate the dates and reason for exclusion?