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So that insiders do not have to wait for the board to meet in order to get approval for additional loans, may the board issue a blanket approval for any future loan requests that exceed the limit that triggers board approval?

Section 215.4(b) of Regulation O permits banks to make loans to covered parties (insiders) up to a certain aggregated amount without the prior approval of the bank's board of directors. The board's prior approval is required, however, for loans that exceed that aggregated loan amount limit. So that insiders who have reached that limit do not have to wait for the board to meet in order to get approval for additional loans, may the board issue a blanket approval for any future loan requests that exceed the limit?

No. See, for example, FDIC Advisory Opinion 81-22 which states that the record of approval "must reflect more than a mere notice of insider borrowing up to a stated amount.” It continues that “[t]he board should be aware of … basic aspects of the loan at the time of approval.” In other words, the board must have something relatively tangible to consider, (e.g., a specific loan request). However, it is possible to approve a line of credit upon which the director may draw, at any time, presuming that it is approved at least every 14 months in accordance with §215.4(b)(3). (February 2021)

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