On Demand Course

The Ins & Outs of Insider Lending and Reg O

Learn how all Reg O limitations involve extensions of credit, but not all extensions of credit are the same.

Rebekah Leonard 2 HR

About This Course

Insider abuse is a real thing.  In finance, insiders hold positions of power or position that can be used to secure sweet loan deals that threaten the very stability of the institution.  There is an entire law devoted to insider lending, and Regulation O implements it. Bank regulators take it all very seriously, with violations bringing civil money penalties, Cease and Desist orders, or even individual permanent removal from the banking industry.  In 2022, a mid-size bank in Maryland paid a $9.5 Million dollar fine for Reg O violations! 

Many compliance professionals shy away from Reg O topics for several reasons: it isn’t a consumer compliance issue, it lives in the realm of Safety and Soundness, and it is downright intimidating.  Nobody wants to tell the Chairman of the Board that their overdraft will not and cannot be paid.  However, it is crucial for compliance officers, auditors, loan staff members, and even operational employees to have a solid understanding of Reg O principles. 

Reg O covers insiders, but who exactly is that?  Directors, principal shareholders, and executive officers.  But who exactly are each of them?  Can you name names? And what about their related interests, such as business ventures, joint accounts, or non-profit representation?  Do you know about all of them, and if they are restricted by Reg O limitations?  You also need to know how to treat bank holding company and affiliate insiders.

Further, there are subcategories of being part of the in-crowd, and not all insider-ness is treated the same.  Some insiders can receive more favors than others.

*This program does NOT qualify, nor meet the National Standard for NASBA accreditation. 

What You Will Learn

After attending this presentation, participants will be able to:

  • Define who is an Insider subject to Reg O limitations.
  • Describe the individual and aggregate loan limits that could apply to various insiders.
  • Explain the best way to protect against overdraft pitfalls.
  • Recognize how adding successful local business customers to your board of directors can suddenly jeopardize all the business loans held by that business-customer-turned director. 

Topics Covered in This Course

  • Detailed explanations of who is an insider is who is not
  • Exploration of related interests
  • What “control” means
  • Detailed descriptions of “extensions of credit”
  • The different lending limits and when they apply
  • When Prior Approval is required, who must get it, and who can grant it
  • What preferential treatment is prohibited
  • What must be reported to the Board (or others?)

Who Should Attend

  • Compliance staff
  • Risk managers
  • Loan policy makers
  • Operations managers
  • Operations staff
  • Legal, and audit

Your Instructor

Rebekah Leonard
Rebekah Leonard

Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.

Training your team?

This course is covered under team memberships.

See Team Memberships
Buying for yourself?
$ 199
Included with Team Membership
Training your team?

This course is covered under team memberships.

See Team Memberships
$ 199
per attendee