All in Regulation O

Agencies Extend Their Statement Regarding Extensions of Credit to Certain Investment Funds

Adam Witmer
Regulatory Update, Regulation O

On December 22, 2022, the OCC, FRB, and FDIC issued a revised interagency statement to extend the “Extension of the Revised Statement Regarding Status of Certain Investment Funds and their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations.” The prior interagency statement, which was issued on December 17, 2021, was set to expire on January 1, 2023.

Fed Extends Reg O Exception for PPP Loans

Adam Witmer
Regulation O, Regulatory Update

On 2/9/2021, the Federal Reserve Board announced the second extension of a rule to bolster the effectiveness of the Small Business Administration's (SBA) Paycheck Protection Program (PPP). Like the earlier extensions, this one will temporarily modify the Board's rules so that certain bank directors and shareholders can apply to their banks for PPP loans for their small businesses.

Fed Extends Reg O Amendment Deadline

Adam Witmer
Regulatory Update, Regulation O

On 7/16/2020, the Federal Reserve Board issued an interim final rule that provides an exception from Reg O for certain Paycheck Protection Program loans guaranteed by the Small Business Administration (SBA). Previously on April 17, 2020, the Federal Reserve Board issued an exception to certain restrictions found in Regulation O for certain PPP loans made to insiders as the Federal Reserve states that PPP loans pose minimal risk. The original Regulation O exception only applied to PPP loans made through June 30 2020 - the original date the Paycheck Protection Program was set to expire. This new amendment to Regulation O extends the existing exception to apply to PPP loans made through August 8, 2020.

Reporting Director Overdrafts for Reg O

Reporting Director Overdrafts for Reg O

Adam Witmer
Regulation O

In this Compliance Clip (video), Adam discusses the overdraft restrictions for directors and executive officers under Regulation O. This video answer the question of whether or not it is a violation of Reg O when a director would have overdrawn his account by $5,000 if the bank had not returned the check for the director. Adam answers this question by diving into the requirements of Regulation O.