[sbs1]

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?

Topic

[rcooper]

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.

[Author]

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