Insider Board Approval is required by Regulation O (Reg O) and imposes limits and restrictions on loans to insiders. It also helps avoid favoritism among insiders and establishes various reporting requirements for insider loans.
This documentation is required if a loan request is from an insider and/or the total exposure (including related interest) will exceed $25,000.
More in-depth information regarding Regulation O may be found on netinterest.
Who is considered an insider?
An Insider is:
- An Executive Officer of Capital City Bank (CCB) or Capital City Bank Group (CCBG)
- Director of CCBG
- Principal shareholder (owns more than 10% of the voting stock of CCBG)
- A related interest of any of the above
- A related interest is any company or entity “controlled” by any of the above.
To see a current list of Insiders, see the Executive Officers Principal Shareholders and Directors list on netinterest. (A list of Insiders may be found on netinterest.)
Note: Community Board Members and associates are not considered insiders.
Approval from the Board of Directors must be obtained before the loan can be closed.
- Consumer Purpose:
- Complete the application in DecisionPro.
- Notify Credit Administration to request polling of Board.
- Business Purpose:
- Complete a credit memo in Abrigo.
- Route a request for presentation to Credit Committee.
Consequences
- Any person involved is subject to fines ranging from $1,000 to$1,000,000 per day. There is no cap on a Reg O violation.
- The bank is subject to a fine of either $1,000,000 or 1% of total assets.
- Associates who extend preferential loans or approve prohibited overdrafts can be fined as much as the insiders who benefit from them.
Once completed, the Insider Board Approval document is uploaded to Synergy (consumer purpose) or Abrigo (business purpose). If all documents are “wet signed”, send to loan servicing in the designated bag.
If you need additional assistance with Abrigo, please contact _Abrigo Help.