Fed extends Regulation O comments on R-1896 to 4 November

The Board of Governors has extended Docket No. R-1896 to November 4, 2026, giving commenters another 30 days on a full restatement of Regulation O, the rule on loans by member banks to their insiders and to insiders of their affiliates. The extension does not adopt new limits. It keeps open a proposal to raise several dollar thresholds, index them to nominal gross domestic product, and rewrite the treatment of passive fund complexes, derivatives and executive officers.

On October 7, 2026, the Board published FR Doc. 2026-20509 at 91 FR 64121. The notice says the August 4, 2026 proposal, 91 FR 49526, “provided for a comment period ending on October 5, 2026,” and that the Board “is extending the comment period for 30 days, until November 4, 2026.” Docket R-1896, RIN 7100-AH27, would amend 12 CFR parts 215 and 225. Nothing in that notice adopts a final rule. The question is what the extension does, and what it does not.

Key facts

• Deadline: November 4, 2026, from October 5, 2026 (FR Doc. 2026-20509, 91 FR 64121).
• Proposal: August 4, 2026, 91 FR 49526, FR Doc. 2026-15777.
• Dollar lines: $15,000 to $60,000; $5,000 to $20,000; $1,000 to $4,000; $100,000 to $400,000; prior approval and disclosure $500,000 to $2,000,000.
• Index: every five years to nominal GDP, with no cut if five-year growth is negative.
• Paperwork estimate: 4,464 recordkeeping respondents and 15,216 annual burden hours.
• FDIC: RIN 3064-AG26 also closes November 4, 2026 (91 FR 64629).
• EagleBank order 22-022-CMP-SM assesses $9,524,000 (August 16, 2022 release: $9.5 million).

Methodology and sources

The primary texts are the October 7, 2026 extension, FR Doc. 2026-20509, and the August 4, 2026 proposal, FR Doc. 2026-15777, read as published Federal Register documents. FederalRegister.gov describes its pages as XML renditions and points to the govinfo PDF as the official electronic format, so figures below are taken from those notices. The Board’s October 2, 2026 press release and Michelle W. Bowman’s October 6, 2026 speech are used only for words on federalreserve.gov.

Related:CP13/26 would lift 128 PRA thresholds with GDP

The comparison set is the FDIC proposal at 91 FR 50730 and extension at 91 FR 64629, OCC Bulletin 2025-47, and, for indexing only, the PRA’s CP13/26. The enforcement file is the August 16, 2022 EagleBank release and the linked consent orders. Neither October notice sets an effective date. Current Regulation O stays in force until a final rule takes effect.

What the October 7 notice changes, and what it leaves alone

The October 7 document is one page. The action is “Notice of proposed rulemaking; extension of comment period.” The heading is “[Regulation O; Docket No. R-1896]”. The dates line states: “The comment period for the notice of proposed rulemaking published on August 4, 2026 (91 FR 49526) is extended. Comments must be received by November 4, 2026.” Comments “may be submitted by any of the methods identified in the proposal.”

Those methods are the Board’s proposals website, marked as preferred; mail or hand delivery to Benjamin W. McDonough, Secretary, 20th Street and Constitution Avenue NW, Washington, DC 20551; or publiccomments@frb.gov with the docket number in the subject line. Comments are subject to public disclosure. The extension adds no new RIN and changes no lending limit.

“Since the publication of the proposal, commenters have requested that the Board extend the comment period. An extension of the comment period will provide an additional opportunity for interested parties to consider the proposal and prepare comments. Therefore, the Board is extending the end of the comment period for the proposal from October 5, 2026, to November 4, 2026.”

— Benjamin W. McDonough, Secretary of the Board, signing for the Board of Governors under delegated authority (91 FR 64121, FR Doc. 2026-20509)

The supplementary information repeats that the amendments would update thresholds and index them, address lending to companies “presumed to be controlled by large asset management companies through passive investment funds,” and reorganize the rule. The order is under authority delegated to the Secretary. The official PDF is on govinfo.

The October 2, 2026 press release, issued at 4:00 p.m. EDT, used the same November 4 date and described insiders as executives, directors and major shareholders who could influence lending. The Federal Register notice is the extension. Neither document changed a limit.

What the August proposal would actually rewrite

Regulation O implements sections 22(g) and 22(h). Insiders are executive officers, directors, principal shareholders and companies or campaign committees they control. Terms must match those for an unaffiliated person. The individual limit follows 12 USC 84: 15 percent of unimpaired capital and unimpaired surplus if not fully secured, plus 10 percent if it is. The aggregate limit is generally 100 percent. Knowing receipt of non-compliant credit is barred by 12 USC 375b(7). The Board would restate the part.

The proposed prior-approval test under Docket R-1896 is the point at which a member bank needs approval from a majority of the entire board before further credit to an insider. Today, as the proposal describes 12 CFR 215.4(b), approval is required when aggregate credit exceeds the higher of $25,000 or 5 percent of unimpaired capital and unimpaired surplus, and the bank may not go above $500,000 without that vote. The interested party must abstain. The August 4, 2026 text would replace the overlap with one test: approval if the new credit, aggregated with all other credit to that insider, exceeds the lesser of 5 percent of unimpaired capital and unimpaired surplus or $2,000,000. The public-disclosure trigger in 12 CFR 215.9(b) would move from $500,000 to $2,000,000 as well. The dollar figure would then be adjusted every five years for cumulative nominal GDP, and would not fall if that growth is negative. Comments on the redesign now run to November 4, 2026.

The reset uses nominal GDP from the fourth quarter of 1994 to the fourth quarter of 2025, because 1994 was “the most recent year in which the Board considered adjusting any of the thresholds.” Figures are “rounded down to simple whole numbers.” Each proposed value is four times the 1994 column.

Source: 91 FR 49526. Credit cards last moved in 1994; overdraft lines in 1979; the executive-officer and prior-approval lines in 1983.

Other-purpose executive-officer credit, now capped at $100,000, would become the lesser of 2.5 percent of unimpaired capital and unimpaired surplus or $400,000. Chief executive, financial, lending and investment officers would join the presumptive title list. Dodd-Frank section 614 added derivative exposure. The proposal would value it under the risk-based capital rule.

How the Fed, the FDIC, the OCC and the PRA are not on one clock

Sources: 91 FR 64121; 91 FR 49526; 91 FR 64629; 91 FR 50730; OCC Bulletin 2025-47; PRA CP13/26. Read October 12, 2026.

The Board would publish a nominal-GDP scalar every five years. It divides GDP for the year before publication by GDP for the year before the final rule’s effective date. A 2027 effective date, in the proposal’s example, means a 2032 scalar of end-2031 GDP over end-2026 GDP. Thresholds would not fall if five-year growth is negative. The FDIC would adjust on the same five-year cadence. CP13/26 would index 128 UK thresholds from July 1, 2031. It is not an insider-lending rule.

The FDIC matched the $100,000-to-$400,000 and $500,000-to-$2,000,000 increases and the comment date. The OCC has not published its own table in the notices read here. Bulletin 2025-47 withholds action on specified fund-complex portfolio credit if conditions are met. The proposal would limit relief to funds that replicate “the risk and return characteristics of a third-party index.”

“In July, we proposed revisions to Regulation O, which governs the extension of credit by banks to bank "insiders," including bank executives, board members, and major shareholders. Regulation O has not been comprehensively updated since 1979. While the original transaction limits may have been appropriate at that time, these limits create a significant administrative burden on community banks and go beyond what is appropriate or necessary for safety and soundness.”

— Michelle W. Bowman, Vice Chair for Supervision, Board of Governors of the Federal Reserve System (Community Banking Research Conference, October 6, 2026)

Her 1979 date matches a comprehensive rewrite, not every dollar line. The credit-card exception moved in 1994. The executive-officer and prior-approval caps were last revised in 1983. She did not propose repeal of the same-terms test or the percentage-of-capital limits.

What the EagleBank orders still require a board to show

The proposal says sections 22(g) and 22(h) and Regulation O exist to limit insider self-dealing. The dollar figure on that purpose is the EagleBank file, which is not inside the 2026 notices.

On August 16, 2022, the Board fined EagleBank, of Bethesda, Maryland, $9.5 million “for violation of the Board’s insider lending regulation.” Controls from 2015 to 2018 let the bank extend nearly $100 million to entities Ronald D. Paul controlled, “including certain family trusts,” without majority board approval. Order 22-022-CMP-SM assesses $9,524,000 under 12 USC 1818(i)(2). The Paul order puts that related-interest credit at $99 million and assesses $90,000. Sources: the release and the bank order. Raising the cap from $500,000 to $2,000,000 would not cure credit a majority never approved.

What the open proposal means for boards, funds and compliance teams

Until a final rule, prior approval is still required above the higher of $25,000 or 5 percent of unimpaired capital and unimpaired surplus, and in any event above $500,000, with the interested director abstaining. The proposal would switch to the lesser of 5 percent or $2,000,000 and would also bar an interested party from the discussion of an asset purchase or sale with the bank. Minutes that record the vote but not the abstention miss what the EagleBank orders treated as the point of the statute.

Section 215.5 would remain for executive officers, with the larger “other purpose” cap. The inadvertent-overdraft exception would rise from $1,000 to $4,000, not disappear. The proposal calls deletion “overly punitive.” The written overdraft-plan exception would move from $5,000 to $20,000. None of this applies before a final rule. The Paperwork Reduction Act estimate is 4,464 recordkeeping respondents and 15,216 total annual hours, and the Board warns of a “fairly significant” renumbering. Question 53 asks whether every C-suite title should be presumed an executive officer.

Bulletin 2025-47 is the OCC and FDIC statement in force, including for community banks. The proposal would codify a passive-index exception because those companies, the Board says, do not raise the self-dealing problem section 22(h) targets, while treating them as insiders would force “extensive monitoring and recordkeeping systems.” Dollar limits are set separately under 12 USC 375a(4) and 375b(3). See an OCC charter application and a withdrawn Fed and OCC filing.

“These statutory provisions and the regulation are designed to protect banks against potential harm from the conflicts of interest of, and self-dealing by, insiders who are in a position to put their personal or business self-interest ahead of the interests of the banks.”

— Board of Governors of the Federal Reserve System, supplementary information, proposal signed by Benjamin W. McDonough, Secretary of the Board (91 FR 49526, August 4, 2026)

The same notice says thresholds should be updated “consistent with the purpose of protecting banks against potential harm from self-dealing by insiders.” If 1994 is the wrong base, a fourfold rise plus automatic increases moves the line past that purpose. The extension does not resolve it. The Board asks for evidence.

What is still open after November 4, 2026

The next step in the notices is the close of comments, not a final rule. The extension sets no date for Board action and does not adopt the worked example of a 2027 effective date.

Still open are nominal GDP versus the Consumer Price Index, the 1994 baseline, and whether falling GDP should cut the thresholds. The proposal would not, “to reduce the potential for procyclicality.” The FDIC notice, signed by Jennifer M. Jones on October 6, 2026, moves only the FDIC deadline. Bowman’s $10 billion community-bank line is a different project. Reporting clocks are in a separate note. More material is on the regulation desk.

The extension in brief

Docket No. R-1896, published on August 4, 2026, at 91 FR 49526 and extended on October 7, 2026, at 91 FR 64121, would restate Regulation O. Comments close on November 4, 2026. The proposal would take six dollar lines to four times the values in its 1994 column, including prior approval and public disclosure from $500,000 to $2,000,000, and would index them every five years to U.S. nominal GDP without a cut if that growth is negative. The FDIC moved a narrower insider-credit proposal to the same date. OCC Bulletin 2025-47 remains the no-action statement on fund-complex portfolio companies until a final Board rule. The October notices do not make the new numbers effective. The enforcement marker is still the EagleBank order assessing $9,524,000 for Regulation O violations tied to related-interest credit the board majority never approved.

Frequently asked questions

What is Docket No. R-1896?

It is the Board’s proposal to amend Regulation O, 12 CFR part 215, and related parts of Regulation Y, 12 CFR part 225. The text was published on August 4, 2026, at 91 FR 49526, under RIN 7100-AH27. The title is “Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks; Bank Holding Companies.” The Board calls it a restatement that would update dollar thresholds, index them, incorporate statutes and interpretations, and address lending to companies presumed controlled through passive funds. The October 7 notice, 91 FR 64121, only extends the comment period.

When do comments close, and where are they filed?

The Board must receive comments by November 4, 2026. The August proposal had required them on or before October 5, 2026. The extension uses the original filing methods: the Board’s proposals website, marked preferred; mail or hand delivery to the Secretary at 20th Street and Constitution Avenue NW, Washington, DC 20551; or publiccomments@frb.gov with the docket number in the subject line. Comments are publicly disclosed. The FDIC’s separate proposal, RIN 3064-AG26, also closes on November 4, 2026, but those comments go to the FDIC, not onto R-1896.

Which dollar thresholds would rise?

The proposal’s table pairs a 1994 value with a proposed value. Credit cards would go from $15,000 to $60,000, interest-bearing overdraft plans from $5,000 to $20,000, and inadvertent overdrafts from $1,000 to $4,000. Executive-officer credit outside another exception would go from $100,000 to $400,000. Prior board approval and the public-disclosure trigger would go from $500,000 to $2,000,000. The Board scaled nominal GDP from the fourth quarter of 1994 to the fourth quarter of 2025 and rounded down to whole-number multiples. The credit-card line last moved in 1994. The executive-officer and prior-approval lines last moved in 1983.

Does November 4 make the higher limits effective?

No. The October 7 action extends a comment period. It does not amend 12 CFR part 215. Until a final rule is published and takes effect, current tests remain, including prior approval above $500,000 and the $100,000 cap on executive-officer credit that fits no other exception. The FDIC’s October 9 notice is the same kind of document: more time to comment, not a limit now in force. The worked example of a 2027 effective date in the proposal is an illustration of the indexing formula, not a date the extension adopts.

How does the EagleBank penalty relate to these thresholds?

The August 16, 2022 release says weak controls let EagleBank extend nearly $100 million to entities controlled by its then chief executive, including family trusts, without the disclosures and majority-board approvals Regulation O required. Order 22-022-CMP-SM assesses $9,524,000. The order against Ronald D. Paul puts the related-interest credit at $99 million without that approval and assesses $90,000. Those orders turn on approval, abstention and related interests. They do not turn on whether the general dollar line was $500,000 or $2,000,000. A higher 2026 trigger would not, by itself, authorise credit the board never approved.

This article is informational analysis only and does not constitute legal, regulatory, tax, or investment advice. Regulatory frameworks change frequently and interpretation depends on facts and circumstances; primary documents and official regulator guidance always supersede summaries. Firms should consult qualified legal counsel and their relevant supervisory authority before taking any action based on the analysis above.