Archive

REGULATION O – RECENT ENFORCEMENT ACTION

Last month, the Federal Reserve Board (FRB) announced a $9,524,000 fine to be imposed on EagleBank, of Bethesda, Maryland for violations of Regulation O. The bank improperly extended credit to entities owned or controlled by its then-CEO and Chairman, Ronald D. Paul. The FRB: Found that EagleBank had deficient internal controls over insider lending practices between 2015 and 2018: Which allowed the bank to extend credit totaling $99 million to entities that Paul owned or controlled, including certain […]

FRB EXTENDS REGULATION O PPP EXCEPTION

On May 14, 2021, the Federal Reserve Board announced the third extension of a temporary modification to Regulation O that allows certain bank directors and shareholders to apply to their banks for PPP loans for their small businesses. The rule extension, which is effective immediately, applies to PPP loans made from March 31 through June 30, 2021. The rule change will continue to apply if the PPP is extended, with the change ultimately sunsetting on March […]

REGULATION O MODIFIED FOR PPP LOANS

On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register. The final rule excludes from all requirements of Regulation O, except for the executive […]

OTTING MISSTATEMENT

Last week Comptroller of the Currency Joseph M. Otting issued a statement after meeting with Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau. According to the news release (NR 2018-14) from the Office of the Comptroller of the Currency (OCC)  Comptroller Otting stated “Acting Director Mulvaney has helped reduce the burden on the banking system by delaying implementation of his agency’s Home Mortgage Disclosure Act rule, committing to reconsider its payday lending rule, and […]