Regulation O and Related Interest in Nonprofit Corporation
Issue/Inquiry
One of the Bank’s directors also sits on the board of a nonprofit corporation that is applying for a loan from the Bank. The Bank’s director does not have an ownership interest in the corporation, since it is a nonprofit and the director is a minority voting member on the 12-member board, with no controlling influence over policy or decision-making. Does the director’s position on the board of this organization trigger Regulation O restrictions?
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