CRCM practice question 20 of 35

Which of the following transactions is subject to the provisions of Regulation O?

Full set: 459 questions
Answer options
A: Time deposit account held by a director
B: Travel advance to an executive officer outstanding for less than 30 days
C: Extension of credit to a director of an unaffiliated, competing, noncorrespondent bank
D: Extension of credit to a member of the bank's board of directors Correct answer
Correct Answer:
D. Extension of credit to a member of the bank's board of directors
Explanation

Regulation O governs extensions of credit from a bank to its "insiders," which include executive officers, directors, and principal shareholders, as well as their related interests. An extension of credit to a member of the bank's own board of directors falls directly under this definition. The regulation aims to prevent insiders from receiving credit on preferential terms compared to the general public. All loans to insiders must follow specific approval procedures and adhere to lending limits established by the regulation.

Why Incorrect

A. A time deposit is a liability of the bank to the director, not an extension of credit from the bank.
B. Regulation O specifically exempts reasonable travel and business expense advances that are settled in a timely manner.
C. Regulation O applies to a bank's own insiders, not directors of unaffiliated and noncorrespondent competitor banks.

References

1. Board of Governors of the Federal Reserve System. (2021). 12 CFR Part 215 - Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks (Regulation O). Section 215.2(h) defines "Director," and Section 215.3(a) defines "Extension of credit."

2. Board of Governors of the Federal Reserve System. (2023). Bank Holding Company Supervision Manual. Section 3800.0, "Loans to Insiders (Regulation O)," page 1.

3. Fordham University School of Law. (2018). Fordham Journal of Corporate & Financial Law, Volume 23, Issue 4. Article discusses the scope and purpose of Regulation O, confirming its application to a bank's own directors.

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