specifically as follows:
"Title VIII of the Financial Institutions Regulatory and Interest Rate Control Act of 1978 ("Title VIII") prohibits banks that maintain correspondent accounts with each other from extending credit to each others executive officers, directors or principal shareholders unless the extension of credit:
a. Is made on substantially the same terms as those prevailing at the time for comparable transactions with other persons; and
b. Does not involve more than normal risk of repayment or present other unfavorable features.
Banks whose executive officers, directors or principal shareholders have received preferential extensions of credit from other banks are prohibited from opening correspondent relationships with those banks."
AND:
"Title VIII also requires an annual report from each executive officer and principal shareholder but not from directors unless they are principal shareholders or executive officers, of federally insured banks to the board of directors of that bank if they are indebted during the year to a correspondent bank. They are required to report the "maximum indebtedness" of executive officers or principal shareholders, each person's related interest to each bank that maintains a correspondent account for the reporting person's bank, the amount of indebtedness outstanding as of a date ten days before the report is filed, and the terms and conditions, including the range of interest rate, for each extension of credit included in the figure reported as the "maximum amnount of indebtedness. This report need not be made public and must be kept on file at the bank for at least three years, although the appropriate agency may require that reports be kept longer. Reports should not be forwarded to the appropriate federal banking agency unless the agency so requests but the reports are subject to inspection by examiners of the appropriate federal banking agency."