4000 - Advisory Opinions
Home Equity Line of Credit Extended to Executive Officer Prior to May 18, 1992, is Grandfathered Pursuant to Section 306(n) of FDICIA
November 6, 1992
Pamela E.F. LeCren, Counsel
The following is in response to your October 15, 1992 request for an opinion as to the applicability of section 22(g) of the Federal Reserve Act to a home equity line of credit your client extended to one of its executive officers prior to May 28, 1992.
Please be advised that provided the home equity line of credit was extended prior to May 18, 1992, the effective date of the statutory change which made section 22(g) applicable to insured state nonmember banks, the entire home equity line of credit is grandfathered pursuant to section 306(n) of the Federal Deposit Insurance Corporation Improvement Act of 1991.
If you have any further questions, please contact me at (202) 898-3730.