Section 37 of the Illinois Banking Act states that the lending limits are to be “determined by the Commissioner,” meaning that they are to be determined by rule. The rules apply broadly to all “officers, employees, directors or to corporations or firms controlled by them or in the management of which any of them are actively engaged.” But note that loans exceeding the lending limit (the higher of $25,000 or 5% of the bank's capital, surplus and undivided profits, with a ceiling of $500,000) need only receive “prior approval of the board of directors of the bank.” 38 Ill. Adm. Rule 340. Therefore, you should be able to exceed the limits, provided that the loans are approved by the board of directors before they are made.

 Regulation O, which limits loans made to “insiders,” would not apply if the employee is not “an executive officer, director, or principal shareholder” or “any related interest of such a person.” 12 CFR 215.4(a) (general prohibition); 12 CFR 215.2(h) (definition of “insider”).