Reg O under paragraph 3898 subsection 215.8 (b): Is item (2)to be taken as the specific information that is required to be captured on the annual survey or is this a requirement to keep records of extensions of credit on an ongoing basis throughout the year in addition to the annual survey?

It's an ongoing recordkeeping requirement. You have to be able to identify at any point in time any insider credits, their terms, amounts, etc. This usually requires coding them in some way so you can pull reports on demand.

I agree with John. You must know who your insiders are at all times for accountability. You have to know how much you have loaned them for internal limits and you need to know the related interests they are affiliated with, again for loan accountability.

These are ongoing requirements and there should be a conduit between the board promoting these folks and the Credit Dept. tracking the loans. Related interests on new insiders also needs to be communicated to those who lend to these folks.

Thanks for the assistance