Not sure if this answers your question but Section 19 speaks a lot about acts of dishonesty against an insured institution which I assume you are. The de minimis provisions are something she'd need to be measured against regarding bonding etc.
So this is my round about way of saying even if you weren't required she'd probably be required to state it on her application at the next bank and by omitting it would be a dishonest act and she be better off with full disclosure.
So if someone were say trying to help her out of a one time big error in judgment the best thing would be to advise her to disclose it and then use the de minimis portion of section 19 to proof her ability to get bonded.
Or maybe I am reading it all wrong and just served to confuse you more if that is the case my apologies.