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If we have a director that becomes an executive officer and has existing loans that exceed the (25,000. or 2.5 % of capitol ) limit and they are not for the purposes allowed to be over the limit, What are we required to do to get the loans under the limit?
Based on the way the regulation is worded (e.g. extending credit to executive officers in the present/future rather than past), I believe this will generally apply to loans made once they become an Executive Officer, not to loans prior to becoming and Executive Officer.
This supports that opinion: https://www.occ.gov/topics/licensing/interpretations-and-actions/2008/int1096.pdf. You can consult your regulator to confirm their stance.
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