As far as I know, Regulation O hasn’t been amended yet. So based on what information we have at this point, IMO if you have an credit exposure with your repurchase agreements then you should refer to 12 CFR 215.4 and 215.5. The prior approval section in 215.4 applies to all extensions of credit to insiders (exec. officers, directors and principal shareholders and any related interests of these individuals) that exceed the stated threshold. Once Regulation O is amended what’s required should become clearer.
