Is there a requirement that banks track loans to insiders of other banks? I do not see this in Reg. O and am only aware of our obligation to track loans by our insiders. Is this in another rule or regulation? Is it an old requirment that has been rescinded?

It seems to be part of the standard examiner request letter, doesn't it? I don't know of any regulatory requirement, but have been asked frequently over the years for the data.

I agree with PB, the FDIC asks every year for a list of loans to Directors and Officers of other financial institutions. It is not necessarily insiders like Reg O officers since you wouldn't know that info.

I checked with the FRB and my contact there checked with their legal deparment. There is no requirement for us to track loans to insiders of other banks. So I wonder why the regulators are asking for that information?

I think they are checking on compliance with 215.20(b) which prohibits preferential lending by a bank to executive officers, directors, and principal shareholders of another bank when there is a correspondent account relationship between the banks. If you don't know if you are banking executive officers, directors, and principal shareholders of another bank, how can you possibly prove compliance?

Some insiders (executive officers only?) are required to report to their bank when they have extensions of credit from another bank for more than they could borrow at their own bank. Could this be a way for the examiner to try to determine if executive officers are fulfilling this requirement - sort of a back door approach?

Bville:
I don't think this is the ulterior motive. It would be very inefficient and time consuming to keep track of manually by examiners. And with ony partial and incomplete reporting, the results would be worthless. There are too many banks in the world to know if an examiner had a complete picture.