TOPIC: Insider

Reg O Questions - Related Interests, Reporting, Etc.

AVP at a bank ($3.4BUSA)

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?