Is there any requirement to review the accounts of non-bank employee directors(and their related interests) for any reason - like we would for regular employee accounts?

We do monitor for Reg O purposes. We also monitor each of our regular employees accounts at least once per year. We have always included directors on this list but I'm wondering why? They don't work at the bank so there isn't a risk there like we have for regular employees to seek opportunities to steal from the bank.

Maybe there is some type of state law. Thought I'd get some feedback here first before pursuing state requirements.

It would have to be at the State law level. Personally, I have never seen it done.

Thanks rl. I thinks it's overkill to include directors since we have other suspicious activity monitoring in place and they have no access to bank processes, procedures, accounts, etc since they aren't employees BUT we've always included them - I'm a big fan of "just because we've always done it doesn't mean it's the right way / best way now."

I'll continue to pursue the state level issue....and see if anyone else has any responses here.